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HomeMy WebLinkAbout05-5829TIMOTHY C. EGOLF, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY. PENNSYLVANIA V. BARBARA D. EGOLF, Defendant CIVIL ACTION - LAW NO. 05- 0 )? IN DIVORCE CIVIL, TERM NOTICE 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 ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OFPROPERTY, 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 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 TIMOTHY C. EGOLF, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW BARBARA D. EGOLF, :NO. 05- 5,F,29 CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Timothy C. Egolf, who currently resides at 452 West Main Street, Walnut Bottom, South Newton Township, Cumberland County, Pennsylvania, 17266, with a mailing address of P.O. Box 43, Walnut Bottom, South Newton Township, Cumberland County, Pennsylvania, 17266. 2. Defendant is Barbara D. Egolf, who currently resides at 452 West Main Street, Walnut Bottom, South Newton Township, Cumberland County, Pennsylvania, 17266. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on February 28, 1995, Leesburg, Virginia. 5. Plaintiff and Defendant separated on or about October 1, 2005. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. 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. 9. Neither party is now serving in the United Armed Forces, nor have ever served in the United States Armed Forces. 10. Plaintiff requests the Court to enter a Decree in Divorce. By: Paul Bradford Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID 9 71786 VERIFICATION I verify that the statements made in the foregoing Divorce 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 unsworn falsification to authorities. DATE: 01!5 Timothy C. Egolf etitioner ej b r? C 0 c=? L` 1 W f\) tiL ' ) C7 V, IT ID f TIMOTHY C. EGOLF, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW BARBARA D. EGOLF, : NO. 05- 5829 CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Barbara D. Egolf, in the above-captioned action and I certify that I am authorized to do so. DATE: O By: J AdamsEsquire Pe rnev for Defendant n? L: _> -71 Tl -L7 - * N ? TIMOTHY C. EGOLF, Plaintiff V. BARBARA D. EGOLF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05 - 5829 CIVIL TERM DIVORCE PETITION FOR ECONOMIC RELIEF AND NOW comes, Barbara D. Egolf, by and through her attorney, Jane Adams, Esquire, and makes the following Petition for Economic Relief against the respondent, Timothy C. Egolf, as follows: COUNT I - EQUITABLE DISTRIBUTION OF PROPERTY 1. Petitioner is Barbara D. Egolf, who is the Defendant in a divorce action filed under the above-captioned number. Her address is: 452 W. Main St., Walnut Bottom Road, Pa. 17266. 2. Respondent is Timothy C. Egolf, who has a mailing address of P.O. Box 34, Walnut Bottom, Pa., 17266. 3. The parties were married on February 25, 1994. 4. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 5. During the course of the marriage, the parties incurred numerous debts. 6. Plaintiff and Defendant have been unable to agree as to an equitable division of said marital property and debts. 7. Plaintiff is seeking an equitable division of all marital property. WHEREFORE, Petitioner prays this Honorable Court, after requiring full disclosure by the Plaintiff, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. 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. &?U? Barbara D. Egolf, Date: Respectfully Jane dams, Esquire I.D. 0.79465 ,6,4 Youth Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF u ll,} -?- !-?, x.:? ? ? ? <> 0 --<: ?"7 9 Curtis R. Long Prothonotary office of the Protbonotarp 11 Renee K. Simpson Cumberfantl Countp Deputy Prothonotary John E. Slike Solicitor 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 - Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573