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Home My WebLink About95-01976 ~:"> ~n .J -:n . ,J ., ~~ ~~ ~ ~~ ~ ~ ~~~ .... ~ ~ ... ~ 1i ~.... - d<'l g';: n ... ~ ~~I ~ g j ~ 1i ~ <( ~] ~ .. ... ~ "Ill 0- <( > <( !ii~~ t ~ 0. g Z . . - " ~... ~ ~ '" ~ oJ ... . ~ .. :E :> z .J 5 x lD a: t !!! III g ~ . 15 w 0 ~ it < . -~o,j ~ ~~~ ~ :J: ~ l::<(z Z ~ i it 2 ~ . _ x l!) U """"la'lO"U. . ~,...oIO)'''''''';''~lnl...t.'SlI: " 11ull,,, . .. ," \. II" , 'In;-. " - It \ "- . . . ' vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT~, PENNSYLVANIA CIVIL ACTION - LAW 95- I ~ '1(." CIVIL TERM IN DIVORCE TRACY A. SLAY3AUGH, Plaintiff DARON W. SLAYBAUGH, Defendant PETITION FOR SPECIAL RELlEr AND NOW comes Petitioner, Tracy A. Slaybaugh, by and through her counsel of record, Bradley L. Griffie, Esquire, and petitions the court as follows: 1. Your Petitioner is the above-named Plaintiff, Tracy A. Slaybaugh, an adult individual currently residing at 1101 Doubling Gap Road, Newville, Cumberland County, pennsylvania. 2. Your Respondent is the above-named Defendant, Daron W. Slaybaugh, an adult individual currently residing at 201 Conodoquinet Mobile Estates, Newville, Cumberland County, pennsylvania. 3. The parties are the same parties to the above-captioned divorce action where a request for divorce, equitable distribution, alimony, alimony pendente lite, and the payment of counsel fees and expenses has been made by the Petitioner. 4. Despite the fact Petitioner is gainfully employed and attempting to maintain fUll-time employment, she is not able to secure sufficient income to maintain herself and see to her basic daily needs. 5. The Respondent is gainfully employed with an income in excess of THIRT~ THOUSAND and 00/100 ($30,000.00) DOLLARS and is not only able to take care of his basic needs, but is also able financially to provide for financial assistance to the petitioner to see to her basic needs pending this litigation. 6. petitioner has secured the services of Bradley L. Griffie, Esquire of GRIFFIE Ii ASSOCIATES to represent her relative to the instant divorce action. 7. Services have been rendered on behalf of the Petitioner relative to the filing of the Divorce Complaint and relative to the instant petition for which a retainer was to have been paid but the petitioner is without sufficient funds to pay her legal counsel for his services. 8. In this action, personal property appraisal, a real estate (mobile home) appraisal, and possibly an evaluation of a pension will be necessary. 9. Petitioner is without sufficient funds to pay for any professional services relative to the evaluation of marital assets at issue in this case. 10. Petitioner filed a Petition for Spousal support which is docketed to Number 403 Support 1995 and D.R. Number 23,817 which has been challenged by the Respondent. 11. Petitioner has appealed the determination of liability relative to spousal support and that matter is awaiting scheduling for a hearing before the Court. 12. The information and testimony, as well as all exhibits relative to the Petition for Spousal Support, will be the same as those to be presented in the within petition for special Relief. 13. It is appropriate for the Court to hear the matter of spousal support, as well as the relief requested herein, at the same time in the best interest of judicial economy and to preserve funds of the parties. WHEREFORE, Petitioner requests your Honorable Court to order: a. Respondent to provide payment of alimony pendente lite to the Petitioner in an amount to be determined pursuant to the Pennsylvania Rules of Civil Procedure; b. That the Respondent provide the sum of ONE THOUSAND and 00/100 ($1,000.00) DOLLARS as a retainer for counsel fees for the Petitioner; c. That the Respondent be required to deposit the sum of SEVEN HUNDRED FIFT'l and 00/100 ($750.00) DOLLARS in an escrow account to be used for purposes of paying for the services of professional appraisers as necessary in this case; d. That the support appeal hearing presently pending wherein the Petitioner requests that spousal 13upport shall be consolidated with the within Petition and both matters shall be heard contemporaneously; and e. Such other relief as the Court deems just and proper. Respectfully submitted, GRIFFIE & ASSOCIATES ./ ire rth Hanover STreet isle, PA 17013 ';;'(717) 243-555l (BOO) 347-5552 , , c. , , Ir> ~~~~ ',-'\ <T> \./, \ ~- \~ - \-' \ ~ .., -, _ 1\ ''':':'i , \ . Ii, (\ ~ , - ,..J r-l~ , ," ,~ '-"( -.j "- -') 1 -:J 'J . ..~ ,,~, ^~ '- __..1 Y' -,' -.j. {"l ,-", 0 'S 0 . -' '- -1 '..J. - --.~ '-\ ~ - 1'- \/) I "~~ ~ .~ '-y\ , (::) \ ",""\' . , __.J ;~ I (j ~ ~ !i~~ :t: ... l>: ~ ... ii ~ft~ 8 - J ~ l'\ ~ "''; ... ~ ~.~ U j Ul - ... Cl o ~ 0 ~ , ... " ~ < !~ ~~ ~ ~ ~ > ~ "Ul 0. .n ~ a. o z ' ~~e~~ l'\ - " ~~ ~ >. ' ... . . . t.6 ~ 1: ~ ~ :r , 5 t lD Ul II 1 ~ Ul ~ W ~ ~ 8 . :- ~ w 0 ~ it ..; . - ~ 06 o ... ::. l:: < Z Z ~ ~~~~~ ~ v · ~ ir 0 _ I 0 U ~ l!) '" ....."".,.0..11. o.."lIOt O]l\urlt "11'11'" fll"...... "Villi'.'''' . . . . . . ,I TRACY A. SLAYBAUGH, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . v. CIVIL ACTION - LAW . . 95- /filii- CIVIL TERM DARON W. SLAYBAUGH, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend aqainst 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 will proceed without you and a decree in divorce or annulment may be entered llgllinst 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 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 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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. Court Administrator Fourth Floor cumberland County Courthouse CarliSle, Pennsylvania 17013 . , . . v. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT~, PENNS~LVANIA CIVIL ACTION ~ LAW TRAC~ A. SLA~BAUGH, plaintiff DARON W. SLA~BAUGH, Defendant 95~ CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Tracy A. Slaybaugh, an adult individual currently residing at 1101 Doubling Gap Road, Cumberland county, pennsylvania. Ms. Slaybaugh has resided at this address since March, 1995. 2. Defendant is Daron W. Slaybaugh, an adult individual currently residing at 201 Conodoquinet Mobile Estates, Newville, CUmberland county, Pennsyl vania. this address since September, 1989. 3. Plaintiff is a bona fide resident of the commonwealth of Hr. Slaybaugh has resided at pennsylvania and has been so for at least six months immediatelY previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on Hay 2, 1987, in Gardners, Adams county, pennsylvania. 5. There hosve been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the A1'1I\ed Forces of the United states of America or ite Allies. 7. Plaintifr has been advised of the availability of counseling and the right to request that the court require the parties to participate in counseling. Knowing this, plaintiff does not desire that the Court require the parties to participate in counseling. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY/PENNSYLVANIA CIVIL ACTION-LAW NO. 95-1976 CIVIL TERM CIVIL ACTION-IN DIVORCE TRACY A. SLAYBAUGH, plaintiff DARON W. SLAYBAUGH Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301 (c) of the Divorce Code was filed on April 18, 1995. 2. The marriage of plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. 5. 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 prior to a divorce decree being handed down by the court. 6. I am not a member of the arTRed forces, nor in active military service, of the United states of America or the commonwealth of Pennsylvania. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of section relating to unsworn falsification to Date: t;'(-;3 (')'):~' , , TRACY A. SLAYBAUGH, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DARON W. SLAYBAUGH Defendant NO. 95-1976 CIVIL TERM CIVIL ACTION-IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 1B, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. 5. 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 prior to a divorce decree being handed down by the court. 6. I am not a member of the armed forces, nor in active military service, of the United states of America or the Commonwealth of Pennsylvania. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made SUbject to the penalties of lB Pa. C.S., Section 4904, relating to unsworn falsification to Date: /1//~/7J/ ities. ttv.._. DARON W. SLAYBAUG ' .9-' J' , - 0\ ~"'9 i -.;;.. 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