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HomeMy WebLinkAbout00-01882 II i , . . '. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CRYSTAL L. RIEBEL, Plaintiff, CIVIL ACTION - LAW vs. NO. fH. /ffL ~ IL<.- JAMES P. RIEBEL, Defendant. IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 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 judgement 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 grounds 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 at Cumberland County Courthouse, Carlisle, PAI7013. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 ,. 11'1-,,,,'0, ,;..,,-- ,- .<,,-- - I' I'.: :1 :i , I :i Ii t' ~:.,...~ II ! " ,~ . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CRYSTAL L. RIEBEL, Plaintiff, CIVIL ACTION - LAW VS. - . NO. 00 - /71:2- c.;.;--e /~ JAMES P. RIEBEL, Defendant. IN DIVORCE COMPLAINT IN DIVORCE IRRETRIEVABLE BREAKDOWN AND NOW, comes the above named Plaintiff, Crystal 1. Riebel, by and through her attorneys, Weigle, Perkins and Associates, and David P. Perkins, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: I. Plaintiff, Crystal 1. Riebel, is an adult individual presently residing at 220 Fairview Road, Shippensburg, Cumberland County, Pennsylvania, since February, 1998. 2. Defendant, James P. Riebel, is an adult individual presently residing at, 2 Pine View Lane, Millsboro, Sussex County, Delaware, since 1996. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on February 14, 1991, III Millsboro, Sussex County, Delaware. 5. There have been no prior actions of divorce or for annulment between the parties or in any other jurisdiction. 6. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since September, 1993. 9. The Plaintiff requests the court to enter a decree of divorce. MARK, .WEIGLE AND PERKINS - ATTORNEYS AT LAW _ 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 ','-, . """'" .- ...... I! " "f .. ,~ WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. By: WEIGLE, PERKINS AND ASSOCIATES ~~C~ David P. Perkins, Esquire Attorney for Plaintiff Attorney ill # 34342 126 East King Street Shippensburg, P A 17257 717-532-7388 'B"'_ ."',' ,..' MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHlPPENSBURG, PA 17257-1397 -.- - 'Ilr_. ~'".'=>' . _.~, 11 . , VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to auth.Q.rities. ~~~~,] Dated: !) - I Ci --CO MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW _ 126 EAST KING STREET _ SHIPPENSBURG. PA 17257-1397 i-{___ .,!-, . . 'r I! I . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CRYSTAL L. RIEBEL, Plaintiff, CIVIL ACTION -LAW v. No. 2000-1882 CIVIL TERM JAMES P. RIEBEL, Defendant. IN DIVORCE PRAECIPE TO REINSTATE DIVORCE COMPLAINT To the Prothonotary, Curtis Long: Please reinstate the complaint in the above captioned matter. I Ii Iii II DatedG)lC. ~ A~;;;'S/~OO WEIGL~G~TES By: David P. Perkins, Esquire Attorney for Plaintiff Attorney l.D. # 34342 126 East King Street Shippensburg, PA 17257 (717) 532-7388 MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397 " "-- " - " p \ ~,.~ " """"~~~ -~ -~-~-':""...~,..._-"~"' ,-"-~ '" ~~:" ~~ ~~:' :~2~~: _j :.n --.;: f~..) . .- \b I~-" -'-.-~' >~) (J, ~~"' ~ill~~l~~"'?il~'1W!I,'%I'I'~~~~rmj~~~~-W!lffil~~!!!j \.0. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CRYSTAL L. RIEBEL, Plaintiff, CIVIL ACTION -LAW v. No. 2000-1882 CIVIL TERM JAMES P. RIEBEL, Defendant. IN DIVORCE PRAECIPE To the Prothonotary, Curtis Long: Please mark the above-captioned matter satisfied, settled and discontinued. WEIGLE, PERKINS & ASSOCIATES Dated: O~~o bu 1'1'1 '2.>:lj)() Q~ G, ~ By: David P. Perkins, Esquire Attorney for Plaintiff Attorney I.D. #34342 126 East King Street Shippensburg, P A 17257 Telephone (717) 532-7388 WEIGI-E, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 " - "_. , ,_ .."'" c'. .,"~. - '~ ~ . " 01, ~~~ ~iI!1IIA~ '*' CQ ,..,::, (j~ ;,-:- (=. C) '''1 "'--" :--) ".''', ,....: C,' ~ :!!Ii _~II:~jll~l!!<";!Iiflf~II'~illlWl,'~!~~"""I!l\IAAfil!HflI'IfIImIlII\I~1f!