HomeMy WebLinkAbout02-6091GLENN A. SMITH, H,
Plaintiff,
V.
MELANlE L. SMITH,
Defendant.
· IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
· 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 in divorce or annulment may be entered
against you by the Court. A judgment may also be entered against you for another 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
Ofl~ce of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania.
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
GLENN A. SM/TH, II,
Plaintiff,
V.
MELANIE L. SM/TH,
Defendant.
· IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
·
· CIVIL ACTION - LAW
· IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, Glenn A. Smith, II, by and through his
attorneys, Mancke, Wagner, Tully & Spreha, and files the following Complaint in
Divorce:
1. The Plaintiff, Glenn A. Smith, II, is an adult individual currently residing
at 1805 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant, Melanie L. Smith, is an adult individual currently residing
at 1805 Hunter Drive, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this
Complaint.
4. Plaintiff and Defendant are husband and wife having been married on
May 9, 1992, in Camp Hill, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the
part/es in this or any other jurisdict/on.
6. Neither Plaintiff nor Defendant are members of the Pruned Forces of the
United States or any of its Allies.
7. Plaintiffhas been advised of the ava/lability of counseling and that he has
the right to request that the Court require both parties to participate in counseling.
8. Plaintiff avers as grounds on which this action is based are:
A. That the masfiage is irretrievably broken pursuant to §3301(c) of the
Divorce Code; and
B. That as of October 13, 2004, the parties will have hved separate and
apart for a period of at least two (2) continuous years pursuant to
§3301(d) of the Divorce Code.
-2-
WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in
Divorce.
Respectfully submitted,
Mancke, Wagner, Tully & Spreha
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Plaintiff
Date;
-3-
VERIFICATION
I verify that the statements made in the foregoing
document are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
GLENN A. SMITH, II,
Plaintiff,
V.
MELANIE L. SMITH,
Defendant.
- IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
' NO: 200245091
· CIVIL ACTION - LAW
· IN DIVORCE
PRAECIPE TO TRANSMIT ~ RECORD
TO THE PROTHONOTARY:
TRANSMIT the record, together with the following information, to the Court for entry of
a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(¢), 33~) of the
Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the Complaint: January 3, 2003, by certified mail,
restricted delivery, remm receipt requested.
3. (Complete either paragraph (a) or (b):
(a)
Date of execution of the Affidavit of Consent required by Section 3301(c)
of the Divorce Code: By Plaintiff: 04/21/03
By Defendant: 04/17/03
(b) 0)
Date of Execution of the Plaintiff' s Affidavit required Section
3301(d) of the Divorce Code:
(2) Date of service of the Plaintiff's Affidavit unto the Defendant:
4. Related claims pending: None
5. Indicate date and manner of service of the Notice of Intemion to File Praecipe to
Transmit the Record, and attach a copy of said Notice under Section 3301(d) (1Xi) of the
Divorce Code: ~~~~~, B-~.
Attorney for Plaintiff
INTHE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~~ PENNA.
NO.
GLFNN A. SMITH, II
VERSUS
MELANIE L. SMITH,
boq/
2002-699~ CML TE~4
DECREE IN
DIVORCE
AND NOW,
DECREED THAT
~T,FNN A. SMITH, II
~~ , IT IS ORDERED AND
, PLAINTIFf,
AND
DEFENDANT,
ARE DIVORCED FROM ThE BONDS OF MATRIMONY.
ThE COURT rETAINS jUrISDiCTION OF ThE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
Jo
PROTHONOTARY