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IN THE COURT OF COMMON PLEAS 0
CUMBERLAND COUNTY, PFNNSYLVANI
CIVIL ACTION - LAW
RNEST JACKSON, III
Plaintiff
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EBRA JACKSON,
Defendant
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DIVORCE COMPLAINT
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Camp HUJ. PA 17011
(7171 73H956
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ERNEST JACKSON, III
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, f'l- 6'7'7 3 (!;,~I.~
v,
DEBRA JACKSON,
Defendant
IN DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claim set
forth in the following pages, you must lake prompt aclion, 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 for any other claim or relief requested in these papers by the Plaintiff,
You may lose money or property or other rights Imporlantto you, including custody or
visitalion of your children,
When the ground for divorce Is indignities or irretrievable breakdown of the
marriage, you may request marriage counselling, 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, 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,
COURT ADMINISTRATOR
CUMBERLAND CO COURTHOUSE 4th FLOOR
1 COURTHOUSE SQUARE
CARLISLE PA 17013 3387
(717) 240 6200
ERNEST JACKSON, III
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 9'1, j' /73 G..,:-< 7h-
v,
DEBRA JACKSON,
IN DIVORCE
Defendant
COMPLAINT
1, The Plaintiff is ERNEST JACKSON, III, who currently resides at310 Cameron
Street, Marysville, Perry County, Pennsylvania 17053,
2, The Defendant is DEBRA JACKSON, who currently resides at11 Wayne Road,
Camp Hill, Cumberland County, Pennsylvania 17011.
3, Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for at least six (6) months immediately previous to the filing of this
Complaint.
4, Plainliff and Defendant were married on September 29, 1990 in Cumberland
County,
COUNT I - DIVORCE
5, Paragraphs 1 through 4 of this Complaint are incorporated herein by reference
as though set forth in full,
6, There have been no prior actions of divorce or for annulment between the
parties,
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. '. . .
7, Divorce is sought pursuant 10 the provisions of the Divorce Code, Sections
3301(c) and 3301(d), in that:
a) The marriage is irretrievably broken;
b) The Plaintiff and Defendant have lived separate and apart since August
17, 1997 and continue to do so; at the appropriate time the Plaintiff will file the appropriate
affidavits,
8, The Plaintiff has been advised of the availability of counselling and of the
Plaintiff's right to request that the Court require the parties to participate in counselling and
does not request same,
9, The Plaintiff is a member of the Pennsylvania Army National Guard. The
Defendant is not a member of the armed services,
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant.
COUNT II - CUSTODY
10. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference
as though set forth in full.
11, The parties are the parents of three children; Aramis Jackson, born July 20,
1991; Rebekah Jackson, born May 8, 1993; Courtney Jackson, born October 3, 1996,
12, They are currently in the custody of the mother at 11 Wayne Road, Camp Hill,
Pennsylvania, 17011,
13, In the children's lifetime for the last five years they have resided at the
following addressees with the following persons;
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Debra Jackson (Mother)
Address
11 Wayne Road
Camp Hill, PA 17011
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August 17, 1997 to
Present
Ernest Jackson, III (Father)
Debra Jackson (Mother)
11 Wayne Road
Camp Hill, PA 17011
August, 1994 to
August, 1997
Patricia & Homer Miller
(Maternal Grandparents)
Ernest Jackson, III (Father)
Debra Jackson (Mother)
6171 50mmerset 51.
Harrisburg, PA
November, 1991 to
August, 1994
14, The children were born during wedlock,
15, The Plaintiff is the father, Ernest Jackson, III and he resides with his parents
Ernest Jackson, Jr. and Louise Jackson and Verna Holmes (Grandmother),
16. The Defendant is the mother, Debra Jackson and she resides wilh the children
at 11 Wayne Road, Camp Hill, Pennsylvania,
17, There has been no other aclions for custody in any other jurisdiction,
18, It is in the best interesl of the children that:
a) The parties have shared legal custody;
b) The Father/Plaintiff have frequent and continuous contact at times to
be determined at the conciliation conference;
c) The Mother and Father are both fully capable and fit parents to raise
the children,
.
,
WHEREFORE, the Plaintiff respectfully requests this Honorable Courl to order shared
physical and legal custody of the parties minor children as to be determined at the custody
conference, or a subsequent Court hearing.
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Respectfully submitted,
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Date: (J~IUl 1, 1~~1
VERIFICATION
I, Ernest Jackson, III verify thaI the statements made In the foregoing Petition are true
and correct to the best of my knowledge, Information and belief. I understand that false
statements made herein are made subject to Ihe penalties of 18 Pa. C.S, Section 4904,
relating to unsworn falsification 10 authorities,
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