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Home My WebLink About06-5513r1. v Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ALICE SHERMAN MOREY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. (Q? - Ss?3 ?L U ll ??fL. VANCE D. MOREY, CIVIL ACTION -LAW Defendant 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 rights important to you, including custody and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ALICE SHERMAN MOREY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. v1a- - 5 s1.2 e iv ??,??yyy VANCE D. MOREY, Defendant CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Alice Sherman Morey, an adult individual residing at 2900 Morningside Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Vance D. Morey, an adult individual residing at 905 Maplewood Lane, Enola, Cumberland County, Pennsylvania 17025. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on December 1, 2001 in Camp Hill, Cumberland County, Pennsylvania. 5. There are no minor children born of this marriage. 6. The parties separated on July 15, 2006. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with § 3301 of the Pennsylvania Divorce Code. COUNT II EQUITABLE DISTRIBUTION 12. The averments in paragraphs 1 through 11 of Plaintiffs Complaint are incorporated herein by reference thereto. 2 13. The Plaintiff 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. WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance with Section 401(d) of the Pennsylvania Divorce Code. COUNT III SUPPORT. ALIMONY PENDENTE LITE AND ALIMONY 14. The averments in paragraphs 1 through 13, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 15. Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. WHEREFORE, Plaintiff, ALICE SHERMAN MOREY, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Awarding Plaintiff support, alimony and alimony pendente lite; C. Equitably distributing the marital property; and D. Awarding other relief as the Court deems just Dated: ?51bCp Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 4 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ALICE SHERMAN MOREY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 6 4 -57S"lJ VANCE D. MOREY, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: 0q1111,16 ALICE SHERMAN MOREY Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ALICE SHERMAN MOREY, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. VANCE D. MOREY, Defendant NO. CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, ALICE SHERMAN MOREY, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated:, 2006 06?e ALICE SHERMAN MdREYV . ? Q mm F- P ?1 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ALICE SHERMAN MOREY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006 - 5513 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE Complaint in the above-captioned matter via by United States Mail, Certified Mail Return I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served the Divorce Receipt Requested, Certificate No. 7003 0500 0001 6561 3160 on the above-named Defendant, Vance D. Morey on October 3, 2006 at his last known home address of 905 Maplewood Lane, Enola, Cumberland County, Pennsylvania 17025. The original receipt and return receipt card are attached hereto as Exhibit "A". V. VANCE D. MOREY, Defendant I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false subject to penalties of 18 Pa. C.S.A. §4904 relating to Dated: October , 2006 made herein are authorities. Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff r s --1 O 1 . • ..0 r-j (Domestic Mail Only; No Insurance Coverage Provided) M For delivery • r-q E1 1.t1 P 17MS `B Postage $ $0.61", 00711 C3 Certified Fee $2.40 i 03 1. Return Reciept Fee r JFdsJr?rR^ t??` (Endorsement Required) 1 , $•! r /?? ?L?•,t 0 Restricted Delivery Fee C? I C3 (Endorsement Required) !4,l?t?j ? C Lr) 0 CID Sri`! j / Total Postage & Fees $ 1-09 0 -1006 M ?j O Sent To o ?+1t' . UGC r1C.t?, 1'?1 t' -------------------------------`---?- -------U -------- ; -i----------- f? fieet, Apt. No i , - or PO Box __C?t--?.r. ve-- /xJR^ Ctty, State, ZIP+4 C ¦ Oompk to Items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Prim 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: M r . \(QK-)(-, z T,-,3 - Cy'Nor " C? D5 CV-)C.- ?, u ca one `E'rNaa- V j o-?L-rj as re X o d?dressss 7&' A-) A?914 g, (xtu C. Date of Delivery aAct. U, D. is delivery address dMianift from item 14 ? Yes If YES, enter delivery addr A No 3. Service Type ? O CsAHied Meg 13 ecpe eil_ ., C3 Registered 0 Return Recelpt for Merchandise O Insured Mali O C.O.D. 2. Article Number 7003 0500 0001 6561 3160 (?Mns w from service AW Ps Forth 3811, February 2004 Domestic Return Recut 10250-M-* 1540 EXHIBIT "A" nJ "'Fl Mir Z1?- ! C_) t? Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor nin-. 5'553 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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