Loading...
HomeMy WebLinkAbout97-03825 ~ ~ $ z ~ ~ ~ "< . I) 7 ~ ~ J ll) <0 00 ('f) I t- O- .1 () "< JAMES L. NBUSBAUM, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . G~J.Q,"''''''' v. . NO. '}'7- 3:j ,) s . . . : 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 "--'., ,... r- I I \ I .- J. 'f ly~ J~ l1..,,- J Market Square Building ,; 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 0) .....'.~'.1 ,0 _..-....._, ,.-.-.-.-...,-........---....-.,.- _. -_.~-._~.-~---._--_.,'----_._- /*-'... ..', .. .. -i' , , ,~ -. : ,,'1 JAMES L. NEUSBAIIH. Plaintiff v. !tAT E. NEUSBAUH. Defendant ,-IJns 6' .:) t' ,- f'eI, tLT5-' . (;~~.:J) COIPWlIT IN DIVORCE .JOHN ~. EAkIN .~'" ., t," --._* fiW-___ 1Jl.I<L~ MI:~, ~ l'2O!l.e. ~,,:;. , ,., \ , ;j2. t 1*".r.,.13 ~ _...._-....,._""._...~..-.,-_.....-~---,.,..'--.,...,...-,.;.,-