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HomeMy WebLinkAbout03-0522CARLY MICHELLE ORRIS, Plaintiff VS. BRIAN D. ORRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003 - 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 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 ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. 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 1-800-990-9108 CARLY MlCi-.~ I I:: ORRIS, Plaillilf VS. BRIAND. ORRIS, IN TIE COURT OF COMMON pi FAS CUMBERLAI~[) COUNTY, PENNSYLVANLA Ne. O3- ~ CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. The Plalnlfff is Carly Michelle Orris, an adult individual, who currently resides at 329 4th Street, 2nd Floor, New Cumberland, Pennsylvania 17070 and whose social security number is 186-62- 4533. 2. The Defendant, Brian D. Orris, is an adult individual, who currently resides at 322 Reno Street, New Cumberland, Pennsylvania 17070 and whose social security number is 174-62- 4236. 3. Plaintiff and Defendant were marded on September 28,1996 in Harrisburg, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff and Defendant are both citizens of the United States. 7. There has bccn no prior action for divorce or annulment in any Jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. Plaintiff hereby avers that there was one child bom of the marriage. 10. are: Plainlfff avers that the grounds on which this ac0on is based (a) That the marriage is irretrievably broken. (b) That the par'des have been physically separated for a continuous period of two years or more, said date of separation being 1999. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, D~Dils ur K. Dils, ~-squire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of ! 8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. CarlyMic elle Orris '-~ ' CARLY MICHELLE ORRIS, Plaintiff VS. BRIAN D. ORRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003- CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served upon you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301 (d} OF THE DIVORCE CODE 1. The parties to this action separated in 1999 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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. Date: . ~arly ~ichefl~O~s, Plaintiff