HomeMy WebLinkAbout00-02584
BEVERLY K. EYSTER,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2000- :2..SP1 c'(.)~L 'T"E:.IUV\
LEROY C. EYSTER, JR.,
Defendant
CIVIL ACTION - LAW
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 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.
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, PA. 17013
(717) 249-3166
1-800-990-9108
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BEVERLY K. EYSTER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
No. 2000- ;;'s'fY CWJ t.v-
LEROY C. EYSTER, JR.,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE IlNJlER SECTlQN 3301 (~ OF THE
DIVORCE CODE
1. The Plaintiff is Beverly K. Eyster, an adult individual who currently resides at
244 North Enola Drive, Enola, Cumberland County, Pennsylvania 17025 and whose
social security number is 191-46-4233.
2. The Defendant, Leroy C. Eyster, Jr., is an adult individual, who currently
resides at 224 N. Enola Drive, Enola, Cumberland County, Pennsylvania 17025
and whose social security number is 179-44-9063.
3. Plaintiff and Defendant were married on November 5, 1972 in Cumberland
County, Pennsylvania.
-1-
4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for
a period of at least six (6) months prior to this filing.
5. Defendant is not a member of the Armed Services of the United States or its
allies.
6. Plaintiff and Defendant are both citizens of the United States.
7. There has been no prior action for divorce filed in any jurisdiction.
8. Plaintiff has been advised of the availability of marriage counseling, and has
waived said right.
9. There are two children born of the marriage, both of whom are adults.
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10. Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken, or in the alternative:
(b) That the Defendant has offered such indignities to the person of the Plaintiff,
in the injured and innocent spouse, so as to render her condition intolerable and life
burdensome.
WHEREFORE, Plaintiff respectfully requests your Honorable Court
to grant a Decree in Divorce.
Respectfully submitted,
DILS & RUPICH
-.
Diane M. squire
1017 North Front Street
Harrisburg, P A 171 02
(717) 232-9724
I.D. No. 71873
1
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VERIFICATION
I verify that the statements made in this Complaint in Divorce
are true and correct. I understand that raise statements hl:rl:in an; made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn ralsilication
to authorities.
CfJ~~)~ \) )Q L
BeVerlY~ )~
Date: ;"'/-,aO...{)ZJ
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BEVERLY K. EYSTER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
No. 2000-2584 Civil
LEROY C. EYSTER, JR.,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please reinstate the above captioned Complaint in Divorce under Section
3301(c) of the Divorce Code for service upon the Defendant, Leroy C. Eyster, Jr.
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By."
'I Diane M. Rupi h, Esquire
1017 North ont Street
Harrisburg, P A 17102
(717) 232-9724
J.D. No. 71873
Date: July 7,2000
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