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Home My WebLink About05-5821TANNER LAW OFFICES, LLC 1300 Market Street, Suite 6 Lemoyne, PA 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff CHRISTOPHER J. POLNY, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA § TAMMY JO EDMUNDSON-POLNY, § CIVIL ACTION - DIVORCE Defendant § 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 will 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. A list of marriage counselors is available in the Office of the Prothonotary at the First Floor, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 6 Lemoyne, PA 17043 Phone(717)731-8114/Fax (717) 731-8115 Attorney for Plaintiff CHRISTOPHER J. POLNY, § Plaintiff § V. § TAMMY JO EDMUNDSON-POLNY, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - $-A2 I //] 1. L' C ?l CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Christopher J. Polny, by and through his attorney, Tanner Law Offices, LLC, and represents as follows: 1. Plaintiff is Christopher J. Polny who currently resides at 811 Rosemont Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Tammy Jo Edmundson-Polny who currently resides at 11C Richland Lane, Apartment 211, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 5, 1995 in St. Augustine, Florida. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken: Plaintiff and Defendant have lived separate and apart since December 2000 and continue to live separate and apart as of the date of filing this Complaint. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 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 to enter a decree of divorce. Respectfully submitted, Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 6 Lemoyne, PA 17043 (717) 731-8114 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 6 Lemoyne, PA 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff CHRISTOPHER J. POLNY, § Plaintiff § V. § TAMMY JO EDMUNDSON-POLNY, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated in December, 2000 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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: \ 5 VERIFICATION I verify that the statements made in this divorce complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: U 1Af1? c /? \ nna W I r> r" i FJ u? 1 co C :? f`. L;7 rl? C; TANNER LAW OFFICES, LLC 1300 Market Street, Suite 6 Lemoyne, PA 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff CHRISTOPHER J. POLNY, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA § V. § NO. (ys. 5-.6, 91 CiV TAMMY JO EDMUNDSON-POLNY, § CIVIL ACTION - DIVORCE Defendant § CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a copy of the Divorce Complaint filed in the above-captioned matter upon Tammy Jo Edmundson-Polny, by regular, first-class U.S. mail and certified U.S. mail, restricted delivery, return receipt requested, addressed as follows: Ms. Tammy Jo Edmundson-Polny I IC Richland Lane, Apartment 211 Camp Hill, PA 17011 and did thereafter receive same as evidenced by the attached Post Office receipt card dated I I / lw>ladbs Respectfully submitted, Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 1 Postal c3 CERTIFIED MAIL RECEIPT D u-i . (Domestic Mail Only; No insur ance Coverage provided) ° ti `O 77 ru 171 o 7 7 EZI stmark Hera ° u7 ° 2005 S C3 ° rv ent TO T rn 'Sb - F? s?:_ P?1.•r Sheer, Apr: Nd.; " -"'""-'"-----m erPO6axNq.---!?? ? AD S: land -20 --.- City, Slefe, ZIPW II -- . P"... "" -".-.-..-"."•-"" q (Ion PS Form rr ¦ Complete items 1, 2, and 3. Also complete A. item 4 if Restricted Delivery is desired. X ¦ Print your name a address on the reverse so that we can WTI ¦ Attach this card t ior on the front if spa Y 1. Article Addressed to: MIFTammy 5ii Ed I f G?. ?i? ?anct? Lane ??a rnenl P1 Calryo All/ /%T /70// Agent la delivery address different from Rem 1? • U Yes If YES, order delivery address below: "o 3. Service Type y IPartifled Mail 0 Express Mall 0 Registered 0 Return Receipt for Merchandise ? Insured Mail 0 C.O.D. 4. Restricted Delivery? (Exha Fee) ivy. 2. Article Number 7004 0750 0002 7282 0590 (giansfer /ram semke rsbe7) PS Form 3811, August 2001 Domestic Return Receipt 102585 -M-1540 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER J. POLNY, Plaintiff ) NO. 05 -5 82 1 -CV V. ) TAMMY JO EDMUNDSON-POLNY, ) Defendant ) CIVIL ACTION - LAW DIVORCE COUNTER AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE Check either (a) or (b): _(a) 1 do not oppose the entry of a divorce decree. -Z(b) I oppose the entry of divorce decree because (Check (i), (it) or both): _/ The parties to this action have not lived separate and apart for a period of at least two years. _(ii) The marriage is not irretrievably broken. Check either (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. -(b) I wish to claim economic relief which may include alimony, division of property, lawyers fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: 1 '`mot Z.2,1 o,5 Tammy Jo Edm son-Polny, Defendant [7 ~-v? CJ C? r-• ':l ??, ?? Y -: ?T N ? _.. ..,d ^? ., '? r? -' c` t..: -`? C_? ?? ? ? ?< Cindy S. Conley, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant Tammy Jo Edmundson-Polny IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER J. POLNY, Plaintiff ) V. ) TAMMY JO EDMUNDSON-POLNY, ) Defendant ) NO. 05 - 5821 - CV CIVIL ACTION - LAW IN DIVORCE PETITION RAISING MARITAL CLAIMS AND NOW, comes Defendant, Tammy Jo Edmundson-Polny, by and through her counsel, Howett, Kissinger, Conley & Holst, P.C., and files this Petition Raising Marital Claims and in support thereof states as follows: Plaintiff is Christopher J. Polity, an adult individual who currently resides at 811 Rosemont Avenue, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant is Tammy Jo Edmundson-Polny, an adult individual who currently resides at I IC Richland Lane, Apartment 211, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant were married on July 5, 1995. 4. A Complaint for Divorce was filed by Plaintiff on November 8, 2005 in Cumberland County, Pennsylvania. 5. Defendant hereby raises the following marital claims: COUNT I - EQUITABLE DISTRIBUTION 6. The prior paragraphs of this Petition are incorporated herein by reference thereto. Plaintiff and Defendant have legally and beneficially acquired marital property including Plaintiff s military pension. WHEREFORE, Plaintiff requests the Court to equitably divide Plaintiff's military pension. COUNT II - ALIMONY AND ALIMONY PENDENTE LITE 8. The foregoing paragraphs of this Petition are incorporated herein as if set forth at length. 9. Defendant lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment and requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. 10. Defendant is unable to sustain herself during the course of this litigation. WHEREFORE, Defendant requests the Court to enter an award of reasonable temporary alimony until final hearing and permanently thereafter. COUNT III - COUNSEL FEES, EXPENSES AND COSTS OF SUIT 11. The foregoing paragraphs of this Petition are incorporated herein as if set forth at length. 12. Defendant has retained an attorney to defend her in this action and has agreed to pay her a reasonable fee. 13. Defendant has incurred and will incur costs and expenses in defending this action. 14. Defendant is not financially able to meet either the expenses and costs of defending this action or the fees to which her attorney will be entitled in this case. WHEREFORE, Defendant requests the Court to enter an award of interim counsel fees, costs and expenses until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. Date: 1A 672 / j Respectfully submitted, Cindy S. Conley, Esqre HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant Tammy Jo Edmondson-Polny VERIFICATION I, Tammy J. Edmundson-Polny, hereby swear and affirm that the facts contained in the foregoing PETITION RAISING MARITAL CLAIMS are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of IS Pa.C.S. §4904 relating to unworn falsification to authorities. Date: 12/29/05 TAMMY J. DMUNDSON-POLNY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER J. POLNY, Plaintiff ) V. ) NO. 05 - 5821 - CV TAMMY JO EDMUNDSON-POLNY, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE CERTIFICATE OF SERVICE I, Cindy S. Conley, Esquire, counsel for Tammy Jo Edmundson-Polny, Defendant in the above-captioned action, hereby certify that a true and correct copy of the foregoing Petition Raising Marital Claims was served upon Tabetha A. Tanner, Esquire, counsel for Plaintiff Christopher J. Polity, by depositing same in the United States mail, first class, on December 29, 2005 addressed as follows: Tabetha A. Tanner, Esquire TANNER LAW OFFICES, LLC 1300 Market Street, Suite 6 Lemoyne, PA 17043 Date: 1d 11 r? - (i lG ( G d L Cindy S. Conley Esq HOWETT, KISS= 're , CONLEY & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant Tammy Jo Edmundson-Polny ? 'bs O ? O c rJ " ` if ? ? r-; r_?> ? ? ? ? ? f i'1 f r? a ? ?? ? ?,, ??, ? -- ?, < • 0 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 6 Lemoyne, PA 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff CHRISTOPHER J. POLNY, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 05-5821-CV TAMMY JO EDMUNDSON-POLNY, § CIVIL ACTION - DIVORCE Defendant § NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AMENDED AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated in December, 2000 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 1?.? q/0S TANNER LAW OFFICES, LLC 1300 Market Street, Suite 6 Lemoyne, PA 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff CHRISTOPHER J. POLNY, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 05-5821-CV TAMMY JO EDMUNDSON-POLNY, § CIVIL ACTION - DIVORCE Defendant § CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a copy of the Amended Affidavit Under Section 3301(d) of the Divorce Code to be filed in the above-captioned matter upon Tammy Jo Edmundson-Polny, by regular, first-class U.S. mail and certified U.S. mail, restricted delivery, return receipt requested, addressed as follows: Ms. Tammy Jo Edmundson-Polny I 1 C Richland Lane, Apartment 211 Camp Hill, PA 17011 and did thereafter receive same as evidenced by the attached Post Office receipt card dated December 22, 2005. Respectfully submitted, Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: II r?5 R?< lilI lr r( hol-p-, bill l?/? 17ei1 i.a or i A. si X B. ffMived by D. Is delivery address different from item 17 I--I Ye: If YES, enter delivery address below: 13-NO 3. Service Type A Certified Mall 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Feel J Yea 2. Article amlerfrom 7004 2890 0001 3912 5722 (fiansfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Phone (717) 731-8114/ Fax (717) 731-8115 Attorney for Plaintiff CHRISTOPHER J. POLNY, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 05-5821-CV TAMMY JO EDMUNDSON-POLNY, § CIVIL ACTION - DIVORCE Defendant § PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Tabetha A. Tanner on behalf of Plaintiff, Christopher J. Polny. TANNER LAW OFFICES, LLC Dated: June 22, 2007 By: A, Tabetha A. Tanner, Esquire Attorney ID No. 91979 1300 Market Street, Ste. 10 Lemoyne, PA 17043 (717) 731-8114 (717) 731-8115 (Fax) Please enter the appearance of Plaintiff, Christopher J. Polny, Pro Se. By: Chri opher J. Poln , Pro Se 811 1/Rosemont Av nue Ne Cumberland, PA 17070 Dated: C r N >? r; co