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6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. The Defendant is not a member of the Armed Services
of the United States or any of its Allies.
6. The plaintiff avers that the grounds on which the
action is based arel
(a) That the marriage is irretrievably broken.
Or in the alternative,
(b) That the parties are now living separate and
apart, and at the appropriate time, plaintiff will submit an
Affidavit alleging that the parties have livsd separate and
apart for at least two (2) years and that the marriage is
irretrievably broken.
WHEREFORE, Plaintiff requests this Honorable Court to
enter a decree in divorce, divorcing the Plaintiff and
Defendant.
COUNT III EQUITABLE DISTRIBUTION
9. Paragraphs 1 through 6 are incorporated by reference
hereto as fully as though the same were set forth at lsngth.
10. plaintiff and Defendant have legally acquired
property, both real and personal, during their marriage from
June 7, 1966 until February 11, 1995, the date of separation,
all of whirh is "marital property".
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11. Plaintiff and/or Defendant have acquired, prior to
the marriage or subsequent thereto, "non-marital property"
which has increased in value eince ths date of marriage andlor
eubsequent to Its acquisition during the marriage, which
increase in value is "marital property".
12. Plaintiff and Defendant have been unab1s to agree as
to an equitable division of eaid property as of the date of
the filing of this Complaint.
WHEREFORE, Plaintiff requests this Honorable Court to
equitably divide all marital property of the parties.
coulr 1111 ALINaI' P.ID.IT. LIT.. ALl MOl'
13, Paragraphs 1 through 12 are incorporated by
referencs hereto 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 though
appropriate employmsnt.
15. Plaintiff requires reasonable support to adequately
maintain henlelf In accllrdanve with the standard of living
established during the marriage.
WIlF;/(~:Jl'OHIJ:, I'llIinlltt rO'lUBllts this Honllrllble Court. tll
tlnlol IlI1 11\0111111 01 III I 1110 II Y pendellte lite until Ilnlll h..ring
and hereafter enter an award of alimony permanently
I hlHflll fl 61 ,
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COUNT IV' COUNSEL FI16
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.
lB. 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 bs 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,
IJIANt: li. RAIIl:un
AT mMN'\,~ I,' AW
Uti II"~III. )HUn
(:AMP 11111, .." I7UII
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CAROLE A. SCALESE,
PLAINTIFF
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-2412 CIVIL TERM
NICHOLAS J. SCALESE,
DEFENDANT
CIVIL ACTION - LAW
IN DIVORCE
CIRTIrICATE or SERVICE
I hereby certify that a true and correct copy of the
Complaint in Divorce has been served upon the Defendant,
NICHOLAS J. SCALESE, by certified mail/restricted delivery on
the 9th day of May, 1995. The return receipt is attached
hereto as Exhibit "A" and made a part hereof.
Respectfully submitted,
SQUIRE
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CAROLE A. SCALESE,
PllllntllT
: IN THE COURT 011 COMMON PLEAS m"
: CUMBERLAND COUNl'\',I't:NNS\'INANIA
I
v.
CIVIL ACTION - LAW
95.2412 CIVIL TERM
NICHOLAS J. SCALESE,
Defendllllt
IN J)JVORCE
DEFENIlANT'S MARIlJA(;.: COllNSIU.ING AFFn>A VII
The defendant, being duly sworn according to law, deposes and says,
I, I have been advised of the availability of marriage counseling and understand that I may
request that the COUll require that my spouse and I pallicipate in counseling,
2. I understand that the coull maintains a list of marriage counselors In the I'rothonolary's
Office, which list Is available to me upon request.
3. Being 50 advised, I do not request that the coull require that my spouse and I
participate in counseling prior to a divorce decree being handed down
I verifY that the statements made in this alTIdavit are true and correct I understand that
false statements herein made are subject to the pellalties of 18 I'a CS Section 4904, relatillll to
unsworn falsillcation to authoJ1lies
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