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Home My WebLink About95-06494 ,I 1\ (,I I , \ "i"'-' \ .1 ,,1]\ ,I, 'i \, , ,1'\'" '1\1, 11\' ~\ J,,' '\ 'I, , \ " Ii' I, ,III' " I' ,i\ 'oIl 1\1' 1\ . I' I ~, \' ,\1 I, I I \1,. I" , I I \'. d'l I', \,,1,: , \ , , I '" 11;\ " I, II' I,:' " :1 , ,I i'\ ,1,\ I, I I " I I " , , \ \' " II " ' I ~ ;'1 :\ I, , , \\ 'I I .11 , \' ,.,1 ') 1'" ' , I '" \ ,,,' I, 1'\ : ,l' 'I \ " I , " , \,',' I' \I " " I ,\~ ,I I, '\1' , " ,\' y" , ," .. I , \ ,I I ..' I " I' \ " ,I I I ,I " \ ,I ,I I ,,' ; \, Ii 1)' "',i, " I " "I I, 'I ! "I I" \ "~'I' .\' I, :1:" ' 1,', I,' , I ,\, \; I, , ,; I'~ ! .\ , , I " ,,1\\ ~ \' I' \;. ,I 'Ii ,I .,' \,1 I ,';\ d\'; " I "', " ," \, I' I, I' " '" II 'I', " .1 " ,h i'.I/ .:\. 'I ,\' ',I ,\ '.' ,1,' \' II I' ,\ " ,I I' "I' ,I " 'I , \ '1' , ,II \ ,I' I \ , \,1.11' ," ,I I I, , I, ,I . "~I' I I' '\' ',' .\ I' j' ':\,". ,','1' 1'\ "~I II '>.\\ I' I I' ',1,' ~' \ .. I \ \'~ "~I ,I i , \, " iI' " '. .1 ", ,,' ~ \ I'L'\ I" , I " , ,1L,\, '1\ '" 1'1 I ,I , '1 I ,I' ',,1 ,I " I ,I " " ,,' 1,1' , ,III"" I ;,,11 \,.1 ... " " I' ,'" I I I ',1,11 I I :,' " " i'" I' .1,1 ,I I , , " , ,I' " , " I' \, THOMAS H. WALLACB, I IN THB COURT OF COHMON PLBAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW v, I NO, <15' It,tlf'/; Ltt.,j ~,.t I NICKOLA K, WALLACB, I Defendant I IN DIVORCB IOTIC. TO DIP.HD AND CLAIM RIGHTS YOU HAVB BBBN SUBD IN COURT. If you wish to defend ag~inst the claims set. forth ill the fOllowing pages, you must take prompt aotion, You are warned that if you fail to do so, the oase may proceed withQIJt 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 mOlley or property or other rights important to you, inoluding oustody or visitation of your ohildren, Wh.n the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may re'1uest marriage oounseling. A list of marriage counselors is ava lable in the office of the Prothonotary, 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FBES, OR EXPIlNSES BEFORE A DIVORCE OR ANNULMENT IS GRANTBD, 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 TELBPHONB THB OFPICB SBT PORTH BBLOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 ,', THOMAS M. WALLACe, PlaintU f I IN THE COURT OF COMMON PLHAS I CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW I I NO. I I IN DIVORCE v. NICKOLA K. WALLACE, Defendant ~PLAIII'f III DIVOII.CI COUll'! I DIVORel I AND NOW comes the above Plaintiff, Thomas H. Wallace, by hiB attorney, Kathleen Carey Daley, Attorney "t Law, and seeke to obtain a decree in divorce from the above-named Defendallt, upon the grounds hereinafter set forth I 1. The Plaintiff, Thomas M. Wallace, is an adult individual who reddes at 3614 Golfview Drive, Mechaniceburg, Cumberland County, Pennsylvania 17055. 2. The Defelldant, Nickola K. Wallace, ie an adult individual who resides at 3614 Golfview Drive, Mochanicsburg, Cumberland County, Pennsylvania ],7055. 3. The plaintiff and Defendant are sui juris, and both have been bona fide residents of the commonwealth of Pennsylvania for a period of more than six months immediately preceding the filing of this Complaint. 4. The PlaintH f and Defendant were married on March 17, 1984, in New Cumberland, Pennsylvania. II. Neither Plaintiff nor Defelldant h in the military or naval ..rvice of the United State. or it. allie. within the provi.ion. of the Soldier.' and Sailor.' Civil 'Relief Aat of the Conqre.. of 1940 and its Amendments. 6. The cau.e(.) of aation and seotion(.) of Divorce Code under which Plaintiff is proaeeding arel A. Section 3301(a) (2). Defendant hili oOD\Dlitted adultery. B. Seotion 3301(a) (6). Defendant has offered .uoh indiqnities to the ~laintiff, the innooent and injured .pouse, a. to render hiB oondition intolerable and life burden.ome. C. Seotion 3301(0). The mardage of the parties ie irretrievably broken. After ninety (90) day. have elap.ed from the date of the filing of this Complaint, Plaintiff intend. to file an Affidavit oonoenting to a divoroe. Plaintiff believe. that Defendant may also file .uch an Affidavit. D. Seotion 3301(d). The marriage of the partie. ie irretrievably broken. The Plaintiff and Defendant .eparated on or about August 11, 1995. 7. There have been no prior aotions ill divoroe between the parties. , I 8. Plaintiff ha. been advi..d of the availability of aoun.eling and that Plaintiff may have the right to reque.t the partie. to partioipate in coull.eling. 9. The partie. may enter into a written agreement with regard to lupport, oUltody, vi8itation of ohildren, alimony and property divi.ion. In the event that 8uoh an agreement i8 exeouted by the partie., the agreement may be illoorporated by the Court into the final Deoree of Divoroe. WHEREFORE, Plaintiff reque8ts your Honorable Court to enter a Deoree in Divorce, divoroing Plaintiff and Defendant. COUNT II IQUITABLI DI8TRIBUTIO. 10. Paragraph. 1 through 4 of thi8 Complaint are inoorporated herein by reference as though 8et forth in full. 11. Plaintiff and Defelldant have aoquired property, both real and per.onal during their marriage from the date of their marriage until Augu.t 11, 1995, the date of their separation. 12. Plaintiff alld Defendant have been unable to agree a. to an equitable divi.ion of Raid property. WHEREFORB, Plaintiff requests your Honorable Court to equitably divide all marital property.