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Home My WebLink About06-0669 " vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. J@- (y&~ e.:'/ ANDREA PRICE, Plaintiff JAMES PRICE, Defendant : CIVIL ACTION- AT LA W- 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 r-ights 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. 1F 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 (717) 249-3166 )' vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :2Cf)&~ (jr.,r :NO. ANDREA PRICE, Plaintiff JAMES PRICE, Defendant : CIVIL ACTION- AT LA W- IN DIVORCE DIVORCE COMPLAINT WITH CUSTODY CLAIM The Plaintiff, Andrea Price, by and through her attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divorce: COUNT I-NO FAULT DIVORCE--~~ 3301(c) or 3301(d) 1. The Plaintiff, Andrea Price, is an adult individual currently residing 2115 Circle Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, James Price, is an adult individual currently residing at 2115 Circle Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months inunediately prior to the filing of this complaint. 4. The parties were married on June 18, 1994, in Carlisle, 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 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 enter a decree of Divorce in this matter. COUNT II-EQUITABLE DISTRIBUTION--~ 3502(a) 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 jointly, individually, or both, which remains in possession of the individual parties. WHEREFORE, the Plaintiff respectfully requests the Court to equitably divide, distribute, or assign the marital property between the parties in such proportion as the court deems just after consideration of all relevant factors and thereby enter an order of equitable distribution of marital property pursuant to 93502(a) ofthe Divorce Code. COUNT I1I-CUSTODYNISITATION -- ~5303 11. Paragraphs one (1) through (10) are incorporated herein by reference. 12. There are three dependent children to this marriage or by formal adoption as follows: Pamella Price, born August 2, 1998, age 7; Kyle Price, born July 28, 2000, age 5; Adam Price, born February 18, 2003, age 2. The children were not born out of wedlock. 13. The Plaintiff seeks primary physical custody, partial physical custody or visitation of all children born of this marriage a set forth in Paragraph Twelve. 14. The minor children are presently in the custody of the Plaintiff and Defendant, who both reside at the address referenced above in Paragraphs One and Two. 15. During the past five years, the children have resided at the following address(es) with the following persons: Dates: Addresses: List All Persons: CT 1 9 9_~resent 2115 Circle Rd (marital residence) Mother, Andrea Price Father, James Price . 16. The Mother of the children is the Plaintiff, currently residing at the above referenced address, Paragraph One. She is married to the Defendant. 17. The Father of the children is the Defendant, currently residing at the above referenced address, Paragraph Two. He is married to the Plaintiff. 18. The relationship of the Plaintiff to the children is that of natural mother. She currently resides with the following persons: subject children and James Price, Defendant. 19. The relationship of the Defendant to the children is that of presumptive. He currently resides with the following persons: subject children and Andrea Price, PlaintifT. 20. The Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 21. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 22. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. 23. The best interests and permanent welfare of the children will be served by granting the relief requested because: a. Plaintiff can provide the children with adequate moral, emotional, and physical surroundings as required to meet the children's needs; b. Plaintiff is willing to continue custody of the children; c. Plaintiff continues to exercise parental duties and enjoys the love and affection of the children. II 24. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the children have been narned as parties to this action. No other persons are known to have or claim any right to custody or visitation, and therefore no notice will be given of the pendency if this action and the right to intervene, save as to the Defendant. WHEREFORE, the Plaintiff respectfully requests this Honorable Court approve any settlement reached between the parties; or, in the event they are unable to reach a settlement, grant the Plaintiff rights of physical custody and/or visitation. Respectfully submitted, Date: OJ. oJ C<p 51i\$MLL~7L Shana M. Pugh, Esquire Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011 ID# 200952 Tel. (717) 763-1800 'I ANDREA PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. :NO. JAMES PRICE, : CIVIL ACTION- AT LA W- IN DIVORCE VERIFICATION 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. S 4904, relating to unsworn falsification to authorities. Date;)!lla (c ..'. ~ J!) ~ r?( I/l..~, Andrea Price Signature: ~ ~ --- ....i v.l ~ c- o ~ ~ ---.. ;i '\ (") -+ c ~ ~0 7.l'X.) ->-3. ~ --- ,..;-' --1:> o V' - a. ~ "" <:) d 40 ", -.:;:, r~ :f ..- ~~ \ -', <;;;. " ~ ~, -. 1"- <xl :J ~ (" (, r<:- f'::: f ';L ""J '" o v v\ @ .-~ C-.J ~:;:: o ., -.... ..,.. n1~ ( ~'~:;cs (- ~J J.. :~";::~ (,) ..,., r1 co I :2.-:: , ., ~'...: :,C) (;r(1 ~ ~o -< r. u' II ANDREA PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 06-669 Civil Term JAMES PRICE, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAF,CIPF, TO RFINSTATR mVORCR COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Divorce Complaint in the above-captioned matter. Respectfully submitted, Date: (/0 lit G[tJ , (',1 " /' Shana M. ugh, sqli'ire" Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street., Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 200952 Tel. (717) 763-1800 4. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff No. 06-699 CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TIMOTHY L. CROCKER Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA I.D #42524 WELTMAN, WEINBERG & REIS CO, LPA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04966419 ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-699 CIVIL TERM TIMOTHY L CROCKER Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO, LPA ....--: " L-/ By: J Attorney f: laintiff 2718 Kopp rs Building 436 Seve h Avenue Pittsburg ,PA 15219 (412) 43 -7955 WWR# 966419 SWORN TO AND ~Y~RIBED befo\e r e this ~ day pf \.;, 2 6 \ l "'I OTARY PU , 'I , NNSYLVANIA , 'i"A'1 FPE ; CON'lMUN~ - Notarial Seal I' Nt f)'PublC He'ld1d-,Kelly, 03 hen County City Of PltiSDU'(gh, A~\eg NO~. 4, 2009 ~ SSIon Expires My Com" \1 - . _ t Notaries Member. Pel\nsylvaniC'. ASSQCl<l,tlOn 0 '" ,~-:::> c:;..-:l 07,"" o --., -::I -:L...,., nl~~ 6 ""t'. ~~. ""1", }~ ~--:?I 55 '-< ~.~ -- :;:::-" ;;v f''' ~ -- ,. ANDREA PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V A IA vs. : NO. 2006-669 JAMES PRICE, Defendant : CIVIL ACTION- LAW- : IN DIVORCE/CUSTODY PRAECIPE TO WITHDRAW DIVORCE COMPLAINT TO THE PROTHONOTARY: Kindly withdraw the divorce complaint in the above captioned case. Date: November 7,2006 /Marlin ar ey, Esquire ~. Law 0 flces fPatrick F. Lauer, Jr., LL 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 .....', {"" .$ C~: f"...' 53 CT" r-~. ~i:l -T:J ;>.'-- ..,... ~~