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HomeMy WebLinkAbout03-0696HARA S. FREEDMAN, Plaintiff ZACHARY FRANCIS CARBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 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 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 ground for divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 HARA S. FREEDMAN, Plaintiff ZACHARY FRANCIS CARBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 1N DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, HARA S. FREEDMAN, by and through her counsel, Kollas and Kennedy, and respectfully represents as follows in support of the within Complaint: 1. Plaintiff is HARA S. FREEDMAN, an adult individual currently residing at 707 Carol Street, New Cumberland, Pennsylvania 17070. Plaintiff's Social Security Number is 166-46-3543. 2. Defendant is ZACHARY FRANCIS CARBAUGH, an adult individual currently residing at 214 Bridge Street, New Cumberland, Pennsylvania 17070. Defendant's Social Security Number is 208-52-3288. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant attested to a common law marriage on October 29, 2001, in New Cumberland, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiffhas 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. COUNT I - DIVORCE PURSUANT TO §3301(c) OR (d) OF THE DIVORCE CODE 7. Paragraphs ! through 6 of this Complaint are incorporated herein by reference as though set forth in full. 8. The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on January 16, 2003. COUNT H - DIVORCE PURSUANT TO §3301(a) OF THE DIVORCE CODE 9. Paragraphs 1 through 8 of this Complaint are incorporated herein by reference as though set forth in full. 10. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays that Judgment and Decree be entered as follows: (a) As to Counts I and II, that a decree be entered divorcing Plaintiff from the bonds of matrimony with the Defendant pursuant to 23 Pa.C.S. §3301(a) or (c) or (d). DATE: / RESPECTFULLY SUBMITTED, Mary KOLLAS f ANI~KENNED~ I.D. No. 69246 1104 Fernwood Avenue, Suite 104 Camp Hill, Pennsylvania 17011 Telephone: (717) 731-1600 ATTORNEY FOR PLAINTIFF VERIFICATION I, HARA S. FREEDMAN, verify that the statements made in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904, relating to unsworn falsification to authorities. DATE: By: HARA S. FREEDMAN HARA S. FREEDMAN, Plaintiff ZACHARY FRANCIS CARBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-696 CIVIL CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, ZACHARY FRANCIS CARBAUGH, accept service of the PlaintiWs COMPLAINT IN DIVORCE and certify that, as Defendant, I am authorized to do so. New Cumberland, PA 17070 Date: ~_~-~Z~ -03 HARA S. FREEDMAN, Plaintiff ZACHARY FRANCIS CARBAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-696 CIVIL CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, ZACHARY FRANCIS CARBAUGH, accept service of the Plaintiff's COMPLAINT IN DIVORCE and certify that, as Defendant, I am authorized to do so. Z~('CHAR~' FR~CIS CARBAUGH 214 Bridge Street New Cumberland, PA 17070 Date: