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HomeMy WebLinkAbout02-2938TERREAN A. BRUNO, : Plaintiff : NICHOLAS A. BRUNO, JR. , : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- ~ CIVIL TERM CIVIL ACTION - LAW DIVORCE 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 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, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ~ 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 (717) 249-3166 TERREAN A. BRUNO, Plaintiff NICHOLAS A. BRUNO, JR., Defendant IN THE COURT OF COMMON PLEAS OF : NO. 02-2~CIVIL TERM : CIVIL ACTION - I~W : DIVORCE COMPLAINT NOW, this ~q~day of ~ , 2002, comes AND the Plaintiff, TERREAN A. BRUNO, by her attorney, DIANE G. RADCLIFF, in Divorce of which the following ESQUIRE, and files this Complaint is a statement: COUNT I: DIVORCE 1. The Plaintiff is residing at 1010 Road, Pennsylvania. 2. The Defendant is Nicholas A. Bruno, residing at 1043 Brentwater Road, County, Pennsylvania. 3. Plaintiff and/or Defendant the Commonwealth for at least six filing of this Complaint. Terrean A. Bruno, an adult individual South York Dillsburg, York County, Jr., an adult individual Camp Hill, Cumberland have been bona fide residents of (6) months previous to the Plaintiff and Defendant were married on September 10, Drexel Hills, Delaware County, Pennsylvania. 1977 at 2 There have been no prior actions of divorce or between the parties. Plaintiff has been advised of the availability of annulment counseling and the right to request that the Court require the parties to participate The Defendant United States in counseling. is not a member of the or any of its Allies. The Plaintiff avers that the grounds based are: so bo Armed Services of the on which the action is Section 3301(c): The marriage is irretrievably broken; Section 3301(d): The marriage is irretrievably broken and the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. W~EREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. 10. 11. 12. COUI~T II: EOUITABLE DISTRIBUTION Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from September 10, 1977 until the date of separation, all of which is "marital property". Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. W-~EREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. 13. COUNT III: ~IMO~ PEND~NTE LITE, ALIMOI~'Y Paragraphs 1 through 12 are incorporated by reference hereto 4 as fully as though the same were set forth at length. 14. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 15. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. W~EREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. COUNT IV: COUNSEL FEES AND COSTS 16. Paragraphs 1 through 15 are incorporated by reference hereto as fully as though the same were set forth at length. 17. Plaintiff has employed Diane G. Radcliff, Esquire, as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 18. The Plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay the necessary and reasonable fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. Respectfully submitted, Supreme Court ID ~32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff 6 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. Section 4904, relating to unsworn falsification to authorities. TERREAN A. BRUNO 7 C')