FORM 3.2 Petition to Prevent Dissipation of Marital Assets

IN THE COURT OF COMMON PLEAS

OF __________________ COUNTY, PENNSYLVANIA

PLAINTIFF

No.

vs

DEFENDANT

PETITION TO PREVENT DISSIPATION OF MARITAL ASSETS

Petitioner, Husband, files this Petition for Injunctive Relief, and is support thereof, avers as follows:

1. Petitioner is the plaintiff in the above-captioned divorce action.

2. Respondent is the defendant in the above-captioned divorce action.

3. Husband filed a Complaint in Divorce on __________________, 20______, requesting economic

relief, including a request for equitable distribution.

4. Husband has learned that Wife has redeemed Certificates of Deposit in the amount of $20,000 which

are marital property.

5. Based upon Wife's statements, Husband believes that Wife will either remove these funds from the

Commonwealth of Pennsylvania, spend the funds, or secret them in order to defeat his claim to an equitable

distribution of this marital property.

6. Husband further believes that Wife will dissipate, alienate or encumber other marital property of the

parties.

7. Section 3323(f) of the Divorce Code provides in relevant part:

In all matrimonial causes, the court shall have full equity power and jurisdiction and may issue

injunctions or other orders which are necessary to protect the interests of the parties or to effectuate the

purposes of this part, and may grant such other relief or remedy as equity and justice require against

either party... .

8. Section 3505(a) of the Divorce Code provides:

Where it appears to the court that a party is about to leave the jurisdiction of the court or is about to

remove property of that party from the jurisdiction of the court or is about to dispose of, alienate or

encumber property in order to defeat equitable distribution, alimony pendente lite, alimony, child and

spousal support or a similar award, an injunction may issue to prevent the removal or disposition and the

property may be attached as prescribed by general rules.

9. Pennsylvania Rule of Civil Procedure 1920.43(a) provides:

At any time after the filing of the complaint, on petition setting forth the facts entitling the party to relief,

the court may, upon such terms and conditions as it deems just, including the filing of security,

(1) issue preliminary or special injunctions necessary to prevent the removal, disposition, alienation

or encumbering of real or personal property in accordance with Rule 1531(a), (c), (d) and (e); or

(2) order the seizure or attachment of real or personal property; or

(3) grant other appropriate relief.

WHEREFORE, Petitioner, Husband, respectfully requests that this Honorable Court grant the within

Petition for Injunctive Relief and enjoin and restrain Wife from encumbering, dissipating, selling or

otherwise alienating any and all marital assets of the parties.

Respectfully submitted,

__________________

Attorney for Husband

[Verification]