HomeMy WebLinkAbout03-0723PATTY JO DARON,
Plaintiff
LARRY E. DARON, JR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 2003- '7~ CIVIL TERM
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 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 249-3166
PATTY JO DARON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
v. NO. 2003- '72~ CIVIL TERM
LARRY E. DARON, JR,
Defendant
IN DIVORCE
COMPLAINT UNDER SECTION 3301(C ) OR (D)
OF THE DIVORCE CODE
Plaintiff, Patty Jo Daron, by her attorney, Lindsay D. Baird, Esquire, sets forth the following:
1
Plaintiff, Patty Jo Daron, is an adult individual residing at 3166 Ritner Highway, Newville,
Cumberland County, Pennsylvania 17241.
2
Defendant, Larry E. Daron, is an adult individual residing at 3166 Ritner Highway, Newville,
Pennsylvania 17241.
3
The parties were married on July 24, 1999 in Adams County, Pennsylvania.
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.
7
In accordance with Section 3301(c ) of the Divorce Code, the marriage between the parties
is irretrievably 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.
Lindsay~ D.,,~aird', Esq ui
Attorney'"tror the Plaintiff
37 S. Hanover Street
Carlisle, PA 17013
717 - 243-5732
I verify that to the best of my knowledge and belief, the statements in the foregoing document
are true and correct. I understand that false statements herein are made subject to the penalties
of 18 PaCS {}4904 relating to unsworn falsification to authorities.
Patty Jo Dar-(:~, I:~iff - ~