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HomeMy WebLinkAbout00-03582 DAVID C. KESSLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO.2000-J58"d CIVIL ACTION-LAW IN DIVORCE CIVIL TERM CHERI K. KESSLER, Defendant 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 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone: (717) 249-3166 :1 1\ .-~u,."..~"O_, ,~.""""",".,-"",,, '.' - DAVID C. KESSLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- 3.59.2 CIVIL TERM CHERI K. KESSLER, Defendant CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301lC) AND 3301 (0) OF THE DIVORCE CODE 1. Plaintiff is David C. Kessler, an adult individual who currently resides at 58 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Cheri K. Kessler, an adult individual who currently resides at 1515 Shirley Avenue, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 5, 1974, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. I, II - " -y~~~--"<,, . 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER ~~~ Robert L. O'Brien, Esquire 1.0.# 28351 17 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff, David C. Kessler II VERIFICATION I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. c.s. ~ 4904, relating to unsworn falsification to authorities. ~~;J e Cf~ (javid C. Kessler Date:G - 0 - ~D ,I II"