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Home My WebLink About03-1239JAMES C. ANDERSON, SR., Plaintiff VS. SHARON D. ANDERSON, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · No. l~ - I,,~.~ Civil Term · ACTION 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 JAMES C. ANDERSON, SR., Plaintiff VS. SHARON D. ANDERSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. Civil Term : : ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is James C. Anderson, a competent adult individual, who has resided at 611B Geneva Drive, Mechanicsburg, Cumberland County, Pennsylvania since 2001. 2. Defendant is Sharon D. Anderson, a competent adult individual, who resides at 1605 S. Douthit SW, Decatur, Alabama. 3. Plaintiff and Defendant have been bona fide residents of thc Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married in 1993 in Valdosta, Georgia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ames C. Anderson, Sr., Plaintiff Date: Respectfully submitted, Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF JAMES C. ANDERSON, SR., Plaintiff VS. SHARON D. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Cfi- ACTION IN DIVORCE Civil Term AFFIDAVIT OF SEPARATION 1. The parties to this action separated in May 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 my 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: /~Vames C. Anderson, Sr., Plainti JAMES C. ANDERSON, SR., Plaintiff VS. SHARON D. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03 - 1239 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this April 1, 2003, I, Jane Adams, Esquire, hereby certify that on March 28, 2003 a certified true copy of the NOTICE TO DEFEND, COMPLAINT IN DIVORCE AND AFFIDAVIT OF SEPARATION were served, via certified mail, restricted delivery, remm receipt requested, addressed to: Sharon Anderson 1605 Douthit SW Decatur, AL 35601 DEFENDANT Respectfully Subm~itted: /q //Jane Adams, Esquire ~ I.D. No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~. m (I) + ~ i~o~' I o '~ ~ I m I In the Court of Common Pleas of Cumberland County, Pennsylvania No. (5 ~ -- j~5~. Civil.-l~ To Prothonotary 19 Attorney for Plaintiff NO. Filed Term, 19 ~ PRAECIPE 19 , Atty. JAMES C. ANDERSON, SR., Plaimiff VS. SHARON D. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03 - 1239 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this May 2, 2003, I, Jane Adams, Esquire, hereby certify that on April 24, 2003, a certified tree copy of the NOTICE TO DEFEND, COMPLAINT IN DIVORCE AND AFFIDAVIT OF SEPARATION were served, via certified mail, restricted delivery, return receipt requested, addressed to: W. Ware Mordson, Esquire 2628 Barrett St., Suite 100 Virginia Beach, Va 23452 Attorney/Representative of Defendant regarding Virginia action. Respectfully Submitted: ATTORNEY FOR PLAINTIFF a!,. C~mplete items 1,2, and 3. Also complete ,,iF[em 4 if Restricted Delivery is desired. I-I Addressee · print your name and address on the reverse Date of Deliver~ sO that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits, different from item 17 I-I Yes if YES, enter delivery address below: [] No 1. Article Addressed to: r~ ' · · ail [] Express . ._ ~ Certified Ma~ ' t for Merchandise V" ~ '"' ' ---. ---~', I ~ ,~re~.i' [] c.o.d. __--- -- -- ~ ~ Fee [] Yes 2. ArticleNumber 7002 2410 0007 8500 9698 (Transfer from sen/ice la,eli 102595-02'M'0835 ~ 381 1, AuguSt 2001 Domestic Return Receipt UNITED STATES POSTAL SERVICE · Sender: Please print your name, address, and ZIP+4 in this box · I First-Class Mail Postage & Fees Pai usPs Permit No. G-lO h,,llh,,lli ...... II"li:"lh,,l,h,hhhhl,l,,t,h,l,,hl JAMES C. ANDERSON, SR., Plaintiff VS. SHARON D. ANDERSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 03 - 1239 Civil Term ACTION 1N DIVORCE pRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: AND NOW, this 17th Day of December 2003, please mark the above-captioned case discontinued. Respectfully Submitted, //ane Adam~, ]~sq~i~e I.D. No. 79465 36 South Pitt St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF