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JAMES L. NBUSBAUM, . IN THE COURT OF COMMON PLEAS OF
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Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
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v. . NO. '}'7- 3:j ,) s
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: CIVIL ACTION - LAW
KAY E. NBUSBAUM, .
.
Defendant . 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 judgement 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 grounds 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, 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 ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF
THEM.
YOU SHOULD TAXE 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.
Court A~inistrator
One Courthouse Square
Carlisle, Pennsylvania 17013
Telephone (717) 240-6200
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,; Ilechanicabul'9, PA 17055
Attorney for Plaintiff
JAMES L. NEUSBAtlM, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
v. . CIVIL ACTION - LAW
.
: NO. q '7- 3i'..lS'
KAY E. NEUSBAtlM , .
.
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1.) Plaintiff is James L. Neusbaum, who currently resides
at 113 Fourth Street, Boiling Springs, CUmberland County,
Pennsylvania, Second Floor.
2.) Defendant is Kay E. Neusbaum, who currently resides at
113 Fourth Street, Boiling Springs, CUmberland County,
Pennsylvania, First Floor.
3.) Plaintiff has been a bona fide resident of the
Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of this Complaint.
4.) The Plaintiff and Defendant were married on March 6,
1961 at Sault Ste Marie, Michigan.
5.) A prior action in divorce was filed by James L.
Neusbaua, plaintiff against Kay E. Neusbaum on December 20, 1989,
to No. 4078 C 89, in CUmberland COunty, which was dismissed for
failure to proceed under RJA 1901 on october 27, 1992.
6.) The aarriage is irretrievably broken.
7.) Plaintiff ha. been advised that counseling is available
and that Plaintiff .ay have the right to request that the Court
- 1 -
IN mE COURT OF COHKON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 1'1- 3~;J ~.
CIVIL ACTION - LAW
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JAMES L. NEUSBAIIH.
Plaintiff
v.
!tAT E. NEUSBAUH.
Defendant
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COIPWlIT IN DIVORCE
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