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Home My WebLink About96-00293 \ I ~ 1 . ~ 1 ~i I . I -JI I oJ I ~ I 01 \ '. ( ~ i I J' i : ~ ! I ! rf) 0- i (0' ! , I ,.3' .0- .; o Z >- N '- ,<; ('oJ ".; i.~,: IS ~:_~~ ;:~ u,(: C. ".I t -,. ff:' t ... ~.: : @ "J ,'-". , ~~. ';'.-.: <-J . - : ~ '.:~ u'l'" (''\J .. Ct" . ri(,j r- o. f ,;-j :.:~- II.. <'., ::J () c:. 0 <.J ~ """,,' ~ :j., ~ ~ ":::'-11' ~ ,: ~ ';!S ~, 'i~ ~'~ ~ :>- ~ :~ O\~.-;C( - I-~ I-' ~C( 0 1 !i;~z :z .0 . . iE : jjj : ~~'\lo ......' :~ i~ ~o. ~~i\t3 1 ~:) . ......, 0., J 1~ '0 0- :u ;, : :. & ., . . ~ ~ Lr;.,; 'I~,- -- ~ .;, v ~ .~ -..;;. J"\ lc)~ - --~ r( r\ ~ , l. IJ' ;)- ~';:;, 0- :l- '- IV) :It. i\. oJ <S~ t: - :J~!~ ~ ~:/j~ c; U~ ~~ie- Q c:3 \- ;1 -' J <" DIANE G. RADCLIFF A'lTORNF.Y.AT-LAW JUS TRINIlI.f. ROAn CAMP 11I1.1., PA 11011 " \ f".x ';", ." DIANE Eo GREENE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; No, 96 -.J. q 3 C~ T -Vw.\,/ Plaintiff v. ARTHUR J. GREENE, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are wamed that if you fall 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 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 Courthouseo Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALlMONYo DIVISION OF PROPERTYo COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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, Cumberland County Court Administrator Cumberland County Courthouse 1 Courthouse Square, 4th Floor Carlisle, PA 17013 (717) 240-6200 1 DIANE G. RADCLIFF ATTORNF,Y-AT-LAW J448 TRISIlU: ROAn CAMP 1111.1.. PA 17011 ~-.......;..,..-.1,~'-' DIANE E. GREENE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No, ARTHUR J. GREENE, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT AND NOW, this 02~"d1y of ~19 'fe:, , comes the Plaintiff, DIANE E. GREENE, by her attomey, DIANE G, RADCLIFF, ESQUIRE, and files this Complaint In Divorce of which the following Is a statement: COUNT I: DIVORCE 1. The Plaintiff, DIANE E. GREENE, Is an adult Individual residing at 5237 Terrace Road, Mechanicsburg, Pennsylvania, since 1981, 2, The Defendant, ARTHUR J. GREENE, Is an adult Individual residing at 5237 Terrace Road, Mechanlcsburg, Pennsylvania, since 1981. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 17, 1977 at Camp Hili, Pennsylvania, 2 I ^\ DIANE G, RADCLIFF A,-roRNF.V.Al'-..AW 'UI TRINUU. RnAf) CAMP 11I1.1_, I'" nOli 5. There have been no prior actions of divorce or annulment between the partieso 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. 8. The Plaintiff avers that the grounds on which the action is based are: (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 lived separate and apart for at least two (2) years and that the marriage Is irretrievably broken, Or in the alternative, (c) That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render her condition Intolerable and life burdensome, and that this action Is not collusive, WHEREFORE, Plaintiff requests this Honorable Court to enter a decree In divorce, divorcing the Plaintiff and Defendant. 3 COUNT II: EQUITABLE QISTRIBUTIOtj 9. Paragraphs 1 through 8 are Incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have legally acquired property, both real and personal, during their marriage from September 17, 1977 until the present, the date of separation, all of which Is "marital property". 11, Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has Increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase In value Is "marital property", 12, Plaintiff and Defendant have been unable to agree as to an equitable division of said 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, COUNT III: ALIMONY PENDENTE LITE. ALIMONY 13. Paragraphs 1 through 12 are Incorporated by reference 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 her though appropriate employment. DIANE G. RADCLIFF ATTORNF.Y-AT-I.AW SUI TRINIH.I: MOAU CAMP 11I1.1" FA 17011 4 , ' ..' t,' ~ CI 15. Plaintiff requires reasonable support to adequately maintain herself In accordance with the standard of living established during the marriage, WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter, COUNT IV: COUNSEL FEES 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 attomey's fees for said counsel. 18. 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 DIANE G. RADCLIFF ATTORNEY-AT-LAW sua TRINUU, ROAIl CAMP 11I1.1.. PA 17011 5 hereafter as may be 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, , DIANE G. RADCLIFF ATTORNEY.AT.LAW s... TRINDI.E ROAD CAMP lUll.. PA 17011 6 VERIFICATION DIANE E. GREENE verifies that the statements made in this Complaint are true and correct. DIANE E. GREENE understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~U4'fZ r DIANE G, RADCLIFF ATTORNEY.AT.LAW 5"'1 TRINOLF. ROAn CAMP IIILI.. PA 17011 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE E. GREENE, Plaintiff NO. 96-293 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE V. ARTHUR J. GREEN, Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY OF THE SAID COURT: Please reinstate the divorce complaint filed in this matter on January 22, 1996. Respectfully submitted, \ ad 17011 PHONE: 737-0100 Fax: (717) 975-0697 Voice Mail: (717) 558-5518 I.D. No. 32112 Attorney for Plaintiff DIANE G, RADCLIFF 3448 TRINDlE ROAD CAMP Hill, PA 17011 (7171737,0100 , b: ;:~: , ,t ~-- ) ~ o. +' f'J '" ~: .... oj . .~. .. c..: -,"'. i-I'.' (')'. C' l~-, ~. I . " ' "\. (::) , ~.. . - ,.' I,") .; }[L, ..:.i u o -:~/ ~ " ....; c." c:;