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Home My WebLink About02-3602KATHLEEN M. GREENE, Plaintiff V. WILLIAM K. GREENE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. D,~ · : : CIVIL ACTION - LAW : 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 of other rights important to you, including the 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 at the Office of the Prothonotary. 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, PA 17013 717-249-3166 KATHLEEN M. GREENE, Plaintiff V. WILLIAM K. GREENE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O.Z-3&o2- CIVIL ACTION - LAW IN DIVORCE _COMPLAINT IN DIVORCF AND NOW comes the Plaintiff, Kathieen M. Greene, by and through her attorney, Charles Rector, Esquire, and respectfully represents as follows: 1. Plaintiff is Kathleen M. Greene (SS~ 328-38-5222), an adult individual, currently residing at 53 Sunfire Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is William K. Greene (SS~ 192-34-5057), an adult individual, currently residing at 53 Sunfire Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for a period of six months (6) immediately preceding the filing of the Complaint. 4. Plaintiff and Defendant were married on December 2, 1967, in Cook County, Illinois. 5. There has been one prior action for divorce between the parties, which complaint was withdrawn. America. The Plaintiff and Defendant are both citizens of the United States of Count I - Divorce 7. The allegations of Paragraphs 1 through 6 are incorporated herein by reference and made a part hereof. 8. This action is not brought through collusion between the Plaintiff and Defendant, but in sincerity and truth for the reasons set forth within. 9. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of the Divorce Code. 10. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce decree dissolving the marriage between Plaintiff and Defendant. Count II - Equitable Distributioi~ 11. Paragraphs I through 10 of this Complaint are incorporated herein by reference as if set forth at length. 12. The parties have acquired, during the course of the marriage and prior to separation, property, both real and personal, which they own jointly or which was otherwise purchased so as to constitute marital property within the definition and scope of Section 3502 of the Divorce Code. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order distributing the marital property owned by the parties. Count III. Spousal SUDDOrt and/or Alimony Pendent Lite and Permanent Alimony 13. The allegations in Paragraph I through 12 are incorporated herein by reference and made a part hereof, 14. Plaintiff is unable to sustain herself dudng the course of this litigation. 15. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself adequately through appropriate employment. 16. Plaintiff requests this Honorable Court to enter an award of spousal support and/or alimony ~ in her favor PUrsuant to Section 3701 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an award of spousal support and/or alimony ~ until final headng and thereupon to enter an order of alimony in her favor pursuant to Section 3701 of the Divorce Code. Count IV. Counsel Fees, Expenses and Costs of Sbll 17. The allegations of Paragraphs 1 through 16 are incorporated herein by reference and made a part hereof. 18. Plaintiff has retained an attorney to prosecute this action and has agreed to pay him a reasonable fee. 19. Plaintiff has incurred and will incur costs and expenses in prosecuting this action. 20. Plaintiff is not financially able to meet the expenses and costs of prosecuting this action or the fees to which her attorney will be entitled in this case. 21. Plaintiff requests this Honorable Court to enter an award of intedm counsel fees, costs and expenses until fin.al hearing and thereupon such additional counsel fees, costs and expenses as deemed appropriate. WHEREFORE, Plaintiff respectfully requests that, pursuant to Sections 3702 of the Divorce Code, the Court enter an Order directing Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. RESPECTFULLY SUBMI'CI'~~- Camp Hill, PA 17011 (717) 761-8101 Date:. I verify that the statements made herein 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 unswom falsification to authorities. Date: Kathl~en M. Greene '/' - ¢o KATHLEEN M. GREENE, Plaintiff V. WILLIAM K. GREENE, Defendant : IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : : NO. Og-%Lo - : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Matthew Hunt, Private Investigator, hereby certify that I personally served the Complaint in Divorce in the above-referenCed matter to William K. Greene, Defendant, on "3"'L~/-¥ ~ ~t ,2002, at approximately r/': ~_~ o'clock Matthew Hunt Date:~.7 I"~, 2 KATHLEEN M. GREENE, Plaintiff V. WILLIAM K. GREENE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3602 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO ENTER AN APPEARANCE Kindly enter the appearance of Michael D. Rentschler, Esquire as attorney for Defendant William K. Greene in the above-captioned case. Respectfully submitted, ~x Michael D. Rentschler, Esqmre 1300 Market S~eet, Suite 200 Lemoyne, PA 17043 (717) 975-9129 Supreme Court ID # 45836 KATHLEEN M. GREENE, Plaintiff V. WILLIAM K. GREENE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3602 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Please withdraw Plaintiff's Complaint for Divorce and related claims filed on July 29, 2002, in above-captioned matter. Date: RESPECTFULLY SUBMITTED, Charles Rector, Esquire 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Plaintiff