HomeMy WebLinkAbout98-00409MISSING
CASE #
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JOHN D. ANDERSON, IV, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA
v. 98-~~~ - ,~11 ~ ®~~c
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MARIA S. ANDERSON, IN DIVORCE
Defendant
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
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 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 Prothonotary's Office
at the 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 COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 240-6200
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JOHN D. ANDERSON, IV, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY PENNSYLVANIA
v. 98- ~ U `~' Cr.~-~-E~ l .u-Yr--
MARIA S. ANDERSON, IN DIVORCE
Defendant
COMPLAINT
Plaintiff, John D. Anderson, IV, by his attorney, Lindsay D. Baird, Esquire, sets forth the following:
1
Plaintiff, John D. Anderson, is an adult individual residing at 1445 Trindle Road, Carlisle,
Cumberland County, Pennsylvania.
2
Defendant, Maria S. Anderson, is an adult individual residing at 1445 Trindle Road, Carlisle,
Cumberland County, Pennsylvania.
3
The parties were married on July 29, 1989, in New Jersey.
4
Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least
six months prior to the commencement of this action.
5
This action is not collusive.
6
There have been no prior actions for divorce or annulment in this or any other jurisdiction within the
knowledge of the Plaintiff.
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7
In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is
irretrievable broken.
8
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.
WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced
from the Defendant.
~ indsay D. B d, Esquire
Attorney for the Plaintiff
37 S. Hanover Street
Carlisle, PA 17013
717 - 243-5732
I verify that the statements in the foregoing pleading
statements herein are made subject to the penalties of
to authorities.
. I understand that false
to unsworn falsification
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JOHN D. ANDERSON, IV,
Plaintiff
v.
MARIA S. ANDERSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
98-409
IN DIVORCE
PRAECIPE TO DISCONTINUE THE ACTION
To: Curtis R. Long, Prothonotary
One behalf of the Plaintiff, John D. Anderson, IV, kindly discontinue the above-captioned
action in divorce.
Respectfully submitted,
~~
indsay Dare Baird, Esquire
Attorney for the Plaintiff
cc: Mr. and Mrs. John D. Anderson, IV
1445 Trindle Road
Carlisle, PA 17013
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