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Home My WebLink About95-06797 r- 0- r- -' ) " ! ,:. I .';:.., . J I 'V .. .r-. '.:?L. ': iv f~'~ ' "', 'j. t ; ",...,,- , .~ ' '; ,:.., ~ '0: (1) a - 4 ..,\ " ; . 'I .:~ .,.i~ I',,, , . [; '.;,0; :':.' ;',:~; ,'1' " , , ~; "- ,,~ ""f ~~' /, ,r.,'; ',' <~ ':", -- 'j'Y .~~ .01 , (~1 ,.F!: ,;"j oJ JI J '" ",' .'", ;,' .....J . '~ f ~ J ,-"". . -'.. 1){"~:, " ....:- ,-. , ',;':-'-.-' ;,-.'-',. ;;:t -.,'j "r ....;, ",'H't,;:. \~,' '';':'' . ''"'\' ",~,J; .- i'" .-'.f, .-, '\~ ,'" ,'.' ,::. >~"" " ,? ~, . ',;. ' ", -",'!-.' :, :3J..... ~':.; -' -,";';J;,V;:,- ~ ,',)j,:.\. -',""" .,-' " - ~,.'" ; ",''', .~1i;::~qjc!::;; . , .>~ 10_ Z"'_ . :":.-'" .. .:;):,<~ 'i-,"- .:,":X ;i~;~)i'/: -"., ":0",', I :r:\F:- ':'-" '. ,~. ~ ,-- ',f:.,;- ;~.~;:~. . ,..:,:,.:'''; ';~r; ~-'.~: :;:~r~-;:~' __ ;'..':-~~ ~:! ::.~t~'i " ", . -'.> ~,r'.' . JENNIFER PALLONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW IN : DIVORCE, CUSTODY, ALIMONY : EQUITABLE DISTRIBUTION : NO. 95- & 797 CIVIL TERM v. ROBERT A. PALLONE, Defendant l'IOTICE TO DEFEND AND CLAIM RIGHTS You have been sued In court. If you wish to defend against the ctalms 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduted conference or hearing. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717/240-6200 .j t : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : DIVORCE, CUSTODY, ALIMONY, : EQUITABLE DISTRIBUTION JENNIFER PALLONE, Plaintiff v. ROBERT A. PALLONE, Defendant : NO. 95- CIVIL TERM COMPLAINT - COUNT I. DIVORCE UNDER 23 Po.C.S. SECTION 330J(c) AND 33011d) The plaintiff, Jennifer Pallone, by her allomeys, the Family Law Clinic, sets forth the following cause of action: 1. Plaintiff is Jennifer Pallone, who currently resides at 27 S. 18th Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Robert A. Pallone, who currently resides at 1103 Yverdon Drive, Apartment AI, Camp Hill. Cumberland County, Pennsylvania 17011. 3. Plaintiff and defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. 5. 6. parties. 7. 8. Plaintiff and defendant were married on January 23, 1988 in Orlando, Florida. Plaintiff and defendant have lived separate and apart since October 14, 1995. There have been no prior actions of divorce or for annulment between the The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decr:e in divorce dissolving the marriage. COUNT II. Persons Addresses Dates CUSTODY 9. Plaintiff repeats and realleges paragraphs one through eight. 10. Plaintiff seeks custody of the following children: Name Present Residence Age 7, born 6/22/88 6, born 6/27/89 4, born 6/5/91 2, born 5/24/93 Katie Pallone Robert S. Pallone Michael S. Pallone Devin S. Pallone 27 S. 18th Street, Camp Hill, PA 27 S. 18th Street, Camp Hill, PA 27 S. 18th Street, Camp Hill. PA 27 S. 18th Street, Camp Hill. PA The children were not born out of wedlock. The children are presently in the custody of Jennifer Pallone. who resides at 27 S. 18th Street, Camp Hill, Cumberland County, Pennsylvania 17011. During the past five years, the children have resided with the following persons Bnd at the following addresses: Jennifer Pallone 27 S. 18th Street Camp HiI1, PA 17011 10/14/95- Present Jennifer Pallone Robert Pallone 27 S. 18th Street Camp HiI1, PA 17011 6/92-10/14/95 Jennifer Pallone Robert Pallone 6415 Jensen Street Orlando, Florida 5/91.6/92 Jennifer Pallone Robert Pallone Orlando. Florida 1989-5/91 The mother of the children Is Jennifer Pallone, currently residing at 27 S. t8th Street, Cumberland County, Camp Hill, Pennsylvania 17011 She is married. The father of the children is Robert A. Pallone, currently residing at 1103 Yverdon Dr., Apt. A-I, Cumberland County, Camp Hill, Pennsylvania 17011. He is married. 11. The relationship of the plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Katie Pallone Robert Pallone Michael S. Pallone Devin S. Pallone daughter son son son 12. The relationship of defendant to the children is that of father. The defendant currently resides by himself. 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interest and pennanent welfare of the children will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the children since birth; b) Plaintiff provides the children with a home with adequate moral, emotional and physical surroundings as required to meet the children's needs; c) Plaintiff is willing to accept custody of the children; d) Plaintiff continues to exercise parental duties and enjoys the love and affection of the children; IS. Each parent whose parental rights to the children have not been tennlnated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her primary custody of the children, subject to partial custody by the father. COUNT III. ALIMONY 16. Plaintiff repeats and realleges paragraphs one through fifteen. 17. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standards of living established during the marriage. 18. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself through appropriate employment. 19. Defendant is employed as a manager and is financially able to provide for the reasonable needs of the plaintiff. .0_,."><". WHEREFORE, plaintiff requests the court to enter an award of reasonable alimony, and such other relief as the court deems just. COUNT IV. EOUlTABLE DISTRIBUTION 20. Plaintiff repeats and rea lieges paragraphs one through nineteen. 21. Plaintiff and defendant have acquired various items of personal property during their marriage as well as have incurred marital debt. WHEREFORE, plaintiff requests the court to enter a decree dividing the property equitably between the parties and such other relief as the court deems just. Date ::/1-:A 1'" ~~ Certified Legal Intern ~~v- THOMAS M. PLACE ROBERT E. r.AINS KATHERINE C. PEARSON Supervising Attorney GAIL R. SHEARER Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 COMMONWEALTH OP PENNSYLVANIA COUNTY OP CUMBERLAND SS. I verify that the statements made In this Divorce/Custody/Alimony/Equitable Distribution Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. fi4904, relating to unsworn falsification to authorities. Date: 1\- 2'8-Q5 ~Mm;~ ~ Ie fer Pa on l LI'> en >-... .0::. -tS; t.ur;:.;,:! Y:r.t;.>~ -c.;u"l. ~:::8~ 01-_.... I .:....,c(.., Cl~.;~:r.: UJ","L.:~ :.!""~~l<i -~:in.. ::> ::;U = r:>... ::t' ... N = m ". ~ ~ ~ ~ , ~ , ~ \-i I , JBNNIIlER PALLONE, Plaintiff V. ROBERT A. PALLONE, Defendant To the ProIbonolary: IN THB COURT OF COMMON PLBAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN DIVORCE, CUSTODY, EQUITABLE DISTRIBUTION NO. 95- ~ 71/ ') CIVIL TERM PRAECIPE TO PROCRIID IN FORMA PAUPERIS Kindly allow lamifcr Pallone, Plaintiff, to proc:ecd in forma pauperis. I, Artur Komiluk, of the Family Law Clinic, student attorney for the party proceeding in forma pauperis, certify that I believe the party Is unable to pay the costs and that I am providing fn:c legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attacl1ed hereto. Date: /00/7'1- /' / ..; BERT E. S THOMAS . PLACE KATHERINE C. PEARSON Supervising Attorney GAIL R. SHEARER Staff Attorney THB FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: 243-3639 JENNIFER PALLONE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW IN : DIVORCE, CUSTODY, AUMONY, : EQUITABLE DISTRIBUTION : NO. 95- CIVIL TERM v. ROBERT A. PALLONE, Dcfcndant AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED INFORMA PAUPERIS 1. I am thc plaintiff in the above mailer and because of my financial condition am unablc to pay thc fecs and costs of prosecuting or defcnding the action or proceeding. 2. I am unablc to obtain funds from anyonc, including my family and associates, to pay the costs of litigation. 3. I represcnt that the information bclow relating to my ability to pay the fces and costs is troc Bnd correct. (a) Namc: Jennifer Pallone Address: 27 S. 18th Street, Camp Hili, PA 17011 Social Sccurity No.: 590-10-9826 (b) Employment If you are presently cmploycd, state NI A Employer: N/A Address: N/A Salary or wages pcr month: N/A Typc of work: N/A If you are presently unemployed, state Unemployed Date of last employment: Never worked Salary or wages pcr month: N/A Typc of work: N/A (c) Other Income within the past twelve months Business or profession: None Other self-employment: None Interest: None Dividends: None Pension and annuities: None ~ Social security l)enefits: None Support payments: rent plus $550 per month Disability payments: None Unemployment compensation and supplemental benefits: None Workman's compensation: None Public Assistance: WIC for two children Other: None (d) Other contributions to household support (Husband) Name: None If your (husband) is employed, state N/A Employer: N/A Salary or wages per month: N/A Type of work: N/A Contributions from children: None Contributions from parents: None Other contributions: None (e) Property owned None Cash: None Checking account: None Savings account: None Certificates of deposit: None Real estate (including home): None Motor vehicle: Make Chevrolet Celebrity, Year 1985 Amount Owed $ 2,500 Stocks: bonds: None Other: None (t) Debts and obligations Mortgage: None Rent: currently paid by husband Loans: None Other: water: $70 per month heating oil: $150 per month electric: $115 per month food: $150 per week (g) Persons dependent upon you for support (Wife)(Husband) Name: Children, if any: Name: Katie Pallone Age: 7 Robert S. Pallone 6 Michael S. Pallone 4 Devin S. Pallone 2 Other persons: None Name: Relationship: 4. I understand that I have a continuing obligation to infonn the court of , . . improvement in my financial circumstances which would pennit me to pay the costs incurred herein. S. 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 18 Pa.C.S. fi4904, relating to unsworn falsification to authorities. Date ,\. 2.'3-QS ~~fs~ Petitioner . ";,;\i!~}..'~""" . U"> en :c .... ;:!; N ~ ,.. C> = )..~ "',.. ;!S.:! W,-,OX (,)7'0<- L;:o ;- u..T~-J Ol-_~ I C,.c:t,!'\ Q~r.!~ w W::': =lU..,~ Lt..:J:~ ,~ :;.l ~U o \.. '<~"-I'tr__~__._.. ,": .',It.'" "~ <.", l.a " f '.'.,. ComoIotIi.....,ondlorZ'D<__.. Co ~ ~3 1nd"~1Il fl' ":";';""'iN.'"'ZZI;: -"RESYitre"'[A" COlI h C. ~~"IIoo_.'''~'''.Ilra-'''_ ~t:o=g;;;~,,-.~,J_.....- I,T. Tloo_"-wlloIoo......-IIoo_...._....IIoo"'.. 11i-. , , 3. AIllc/e Addrollod 10: : ' ~ PAu.aJ6 : lID:? YV€(<(JOtJ OO\lE' : Prfi1: A-I &IMP HILL PA 170) I , I A~ - '. . f f .. I 8. Add,....o'o Addro.. (OnIV II 'oqUOIlod 'I ond foo '" pold). ~ 4b. Service TVPO ~ ~oglllorod 0 Inlurod Colllnod 0 COD Exp'..1 Moll 0 Return R_lpt fo, 7. Ooto of Doll /-. ~ . Decombe, 18S1 .....ClI'O:'.........1I4 DOMESnC RETURN RECEIPT '" Print your name, address and ZIP Code here . . . -, ..... . . '''l'IJ"-:I'':o.o. " ,,.~.~ - ." \:;~:~:~:r~~ POITAL IIRVIC! , I' I oiIloloI.......... , I ' 1'- I " I' I I. I' ,.,-,_..., \1\1\1 /" PENALlY FOR PRIVATE USE to AVOO PA'IMENT Of POST~ 1300 FAMILY LAW CLINIC 45 N. PITT STREET CARLISLE, PA 17013 ~. ."u~ >.", .' " . " , - g , -.~,.....______U_ ~t,"""-,,."("..':..i,": >", Z 321 !2! 946 ~ Receipt for Certified Men No Inlurance Coverege Provided __ Do not UI. for International Mall ISH Rever"l Ii! ~ I I I c.rt..,f_ Ie Ss*:..,~.f_ ~ -X \ ", ,,"!fitted o.l_. 'H ~ JENNIFER PAU.ONB, Plaintiff : IN THE COURT OF COMMON PLBAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : CIVIL ACl'ION - LAW : DIVORCE, CUSTODY, ALIMONY, : EQUITABLE DISTRIBUTION ROBERT A. PAU.ONB, Defendant . . : NO. 95- ~ 7'1'1 CIVIL TERM CERTIF1CATE OF SERVICE I, Artur Komiluk, Certified Legal Intern, Family Law Clinic, hereby certify that I am ICrVina a true and comet copy of Divorce Complaint on Robert Pallone, residing at 1103 Yvcrdon Drive, Camp Hill, Cumberland County, Pennsylvania, by depositing a copy of the same In the United States mail, certified, restricted delivery, return receipt requested, postaae prepaid, this 30th day of November, 1995. ~ ARTUR KORNILUK Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 I ("') If) M !~ II - L. - $ a.. 9-~ \0 .... I ~~ (,.) w F 0 ::;; ~ In ::> '" u , ,