HomeMy WebLinkAbout95-02304
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15. The parties purchased or otherwise obtained during the course
of their marriage property which is considered "marital
property".
16. upon entry of a divorce decree, such property should be
divided equitably as is just and proper.
COUNT IV - COUNSEL FEES. COSTS. EXPENSES
17. Paragraphs 1 through 16 are hereby incorporated by reference
and made a part hereof.
18. Plaintiff has retained the services of Richard c. Ruben,
Esquire, and the counsel fees, costs, and expenses for
representation in this action will be substantial and
continuing.
19. Plaintiff is without sufficient funds, income, or assets to
pay such counsel, fees, costs, and expenses.
20. Plaintiff will need to retain the services of an appraiser and
other experts with regard to this action.
21. Defendant is financially able to provide for these expenses of
Plaintiff.
COUNT V - ALIMONY AND ALIMONY PENDENTE LITE
22. Paragraphs 1 through 21 are hereby incorporated by reference
and made a part hereof.
23. PIa inti f f lacks suff icient means of support at present to
fully provide for her reasonable needs, despite the fact she
is employed. Plaintiff requests an award of alimony pendente
lite.
24. Plaintiff requires reasonable support to adequately maintain
herself in accordance with the standard of living established
during the marriage.
25. Defendant is financially able to provide for the reasonable
needs of Plaintiff.
COUNT VI - INSURANCE RELIEF
26. Paragraphs 1 through 25 are hereby incorporated by reference
and made a part hereof.
27. Plaintiff lacks sufficient means of support at present to
provide health or life insurance coverage on herself.
2B. Defendant is financially able to carry health and life
insurance coverage personally or through his employer for her
and to carry dental and eye insurance coverage personally or
through his employer for her.
WHEREFORE, Plaintiff prays that a judgment be entered in favor
of the Plaintiff against the Defendant as follows:
a. As to Count I, that a decree in divorce be entered
divorcing Plaintiff from the bonds of matrimony between
the said Plaintiff and Defendant.
b. As to Count II, in the alternative, should Defendant
execute an Affidavit consenting to a divorce because the
marriage is irretrievably broken, that a decree in