HomeMy WebLinkAbout07-0528
01.
ERIN RICHARDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, P A
v.
NO. 67-5a..8 CIVIL TERM
ANTHONY W. RICHARDSON,
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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS'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
32 SOUTH BEDFORD
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166 OR (800)990-9108
ERIN RICHARDSON,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, P A
NO. 07- 5-d'jl CIVIL TERM
ANTHONY W. RICHARDSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT
1. Plaintiff is Erin Richardson, who currently resides at 125 North Washington Street,
Shippensburg, Cumberland County, Pennsylvania 17257.
2. Defendant is Anthony William Richardson, who currently resides at 3371 South 8th
Road, Humansville, Missouri 65674.
3. The Plaintiff has been a bona fide resident in the Commonwealth for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February 14, 1997.
COUNT I - DIVORCE
5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as
though set forth in full.
6. There has been a prior action of divorce between the parties filed by Defendant,
Anthony W. Richardson, in the District Court, 408th Judicial District, of Bexar County, Texas, at
Docket No. 2006CI06878. Undersigned counsel has been unable to make any contact with John T.
Fleming, Esquire, the filing attorney in Texas, to determine the status of the action. Furthermore,
the Defendant is now residing in Missouri.
7. Divorce is sought pursuant to the provisions of the Divorce Code, ~ 3301 (c) and
3301 (d), in that:
a. The marriage is irretrievably broken.
b. Plaintiff and Defendant have lived separate and apart since June 2003, and
continue to do so.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have the
right to request that the court require the parties to participate in such counseling.
9. The Plaintiff in this action is not a member of the Armed forces.
WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce.
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
Kara W. Haggerty
Supreme Court ID 86
36 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 249-0900
Attomry for Plaintiff
DATE DI l!J D
..
VERIFICATION
I, Erin Richardson, verify that the foregoing Complaint in Divorce is true and
correct to the best of my knowledge and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn
falsification to authorities.
Date: ~
.
CERTIFICATE OF SERVICE
-7-J...rL
AND NOW, this ~ day of January, 2007, I, Kara W. Haggerty, Esquire, of Abom &
Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Divorce
Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States
Mail, Certified mail and First-class mail, postage prepaid addressed to the following:
Anthony William Richardson
3371 South 8th Road
lIurnnansviUe,~() 65674
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
Kara W. Haggerty, Esq'
Supreme Court ID 869 4
36 South Hanover Street
Carlisle, P A 17013
(717) 249-0900
Attornry for Plaintiff
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AFFIDAVIT OF SERVICE
I, Kara W. Haggerty, hereby certify that I did serve a true and correct
copy of the Complaint under Section 3301(c) of the Divorce Code, upon the
Defendant, by depositing, or causing to be deposited, same in the u.S. mail,
certified, restricted delivery, postage prepaid, on January 26, 2007, at Carlisle,
Pennsylvania, addressed as follows:
Anthony Richardson
3371 South gb Road
Humansville, MO 65674
Return card acknowledging receipt on January 30, 2007 is attached as
Exhibit "A".
ABOM & KUTULAKIS, LLP
Date:~
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Kara W. Haggerty,
36 South Hanover
Carlisle, P A 17013
(717)249-0900
Attorney for Plaintiff
I.D. No: 86914
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Item 4 If Reeb1cted DelIvery 18 deelr8d.
. PrInt your name 8'1d addr88s on the nwerse
80 that we CII1 return the card to you.
. AtI8ch this cerd to the back of the mallpIece,
or on the front If space permits.
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