HomeMy WebLinkAbout97-00030
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ANDY R. RUSSELL,
Plaintiff
IN THE COURT OF COMMON I)LEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
;
v.
CIVIL ACTION - LAW
AMY J. RUSSELL,
Defendant
NO. 91 - 30 CIVIL TERM
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend Bgainst the claims set forth in
the full owing pages, you must take prompt action. You are warned that if you fail to do
so, the case mBY 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 with 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, First Floor, Cumberland County Court House,
Carlisle, Pennsylvania 17013.
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 TIlE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TIllS 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.
Court Administrator
Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200.
ANDY R. RUSSELL,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
AMY J. RUSSELL,
Defendant
NO. 96- ") CIVIL TERM
IN DIVORCE
COMPLAINT UNDER
SECTION 3301(e) OF TilE DIVORCE CODE
I. Plaintiff is Andy R. Russell, who currently resides at 99 Russell Road, Carlisle,
Pennsylvania 17013, since at least ]985.
2. Defendant is Amy J. Russell, who currently resides at 3 119 Ritner Highway,
Newville, Pennsylvania 17241 since July 21, 1996.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on April 19, 1983, in Loysville, Peny
County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The marriage is irretrievably broken.
7. 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 counseling.
8. Plaintiff requests the Court to enter a Deeree of Divorce.
I verify that the statements made in this 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 Buthorities.
Date:
/ J.')) '17
{ {
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Andy R. Russell
LANDIS, BLACK & SCHORPP
BY'~~
Edward L. ch rpp, Esquire
Attorney for Plaintiff
36 South Hanover Street
Carlisle, PA 17013
(717) 243-3727
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