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HomeMy WebLinkAbout00-05212 ," -..Jr'~c,. " SAUNDRA 1. VANMETER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 5Ji;;( CIVIL TERM MARK A. VANMETER, Defendant : 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 o.:(.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 TIDS 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 AMERICANS WITH DISABIL1TIES ACT OF 1990 The Court of Common Pleas of Cumberland County is JCquired by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. " James J. Kayer, Esquire Attorney for Plaintiff Liberty Loft 4 East Liberty Avenue Carlisle, P A 17013 (717) 243-7922 ",' =- ^~.tII.JV!ai "~'!r~*~~i;!~~i!:I\\1~~i&E.."1lI~'lf ~,~ _",k .J~.."";','~' '< I', ';:"~~li';,;";'''c "~i~.,"."> "'" .,-. ." c-_' "".:..~~..f<":""'~ .1 I 'I I I " ~ - ,'W. ~~ 1'Ii'1~_~ r SAUNDRA 1. VANMETER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2000 - 5:1-/.2.- CIVIL TERM MARK A. VANMETER, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE COMES NOW, Plaintiff SAUNDRA 1. VANMETER, through her attorney, James J. Kayer, Esquire and avers as follows: COUNT I - DIVORCE 1. Plaintiff is SAUNDRA 1. VANMETER, who resides at 38 Mountain View Terrace, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is MARK A. VANMETER, whose current home of record is 38 Mountain View Terrace, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 28, 1988 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce filed in this matter. 6. Plaintiff and Defendant are not members of the United States Armed Forces. 7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of the Divorce Code. 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. _':~':~J.ilk'Jtil~~_~~~.~m:!l1~ -, M:~~W'~ ~"li..MiIMI:~- 11 "'llillllMl1lmm'il!Mft!JilI' --~ . ~ WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, iic r ~ltl~~I5~~IW<i*,~~ilij""~' "",' "" '" If iIIo.r!lit.i'-J ^ , . _llIitiiu ~ _ m_ , '"'''' .' _i_ ,""'-, , " "~i , VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my cOlillsel and not my own. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. I tmderstand that false statements herein are made subject to the penalties of 18 P A. C.S. 9 4904, relating to unsworn falsification to authorities. DateYA j I / ~ ()O \\ 'JOjl/lrhk /;f l/;;;/J~) "~-~ I-a ~~ ~ ""~~ ~~,~~ ~~ i'",',': ' -"',',j-; '~ ""'",iI.!, " SAUNDRA 1. VANMETER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CML ACTION - LAW : NO. 2000 - 5212 CIVIL TERM MARK A. VANMETER, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYL V ANlA : SS. COUNTY OF CUMBERLAND I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, SAUNDRA 1. VANMETER, and that he did serve a true and correct copy of the Notice to Defend and Complaint in Divorce that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, MARK A. VANMETER, on August 4, 2000. The return receipt is attached hereto. Sworn to and subscribed before me IS 9./-.. day of t.d{)OO, TARIAL SEAL DENISE PINAMONTI. Notary Public Carlisle Borough, Cumbe~and County M Commission, E . -2000,~, , '.~~" Co~~te items 1, 2, and 3. Also complete \ ite~'if Restricted Delivery is desired. . Print your name and address on the reverse so 'that we' can return the card to you. . Attach this card to the back 01 the mailpiece. or on Ihe lront il space permits. 1. Article Addressed to: m fIR "- Uf\l-.J rf\e-fQ r ~ f'f\c::u{\\e:.l\l\ \J(~ lQr ~Ol\\~ -?'" ()~l{ \ A. Received by (please Print Clearly) B. Date.Qf..t)elWry .rl~ If tIfw~~ ,'1;i,../)1tJ, C. Signature _.~ -., X F/~ Agent ~ t?- ,./"\ Addressee . D. Is delivery address different from item 1? ,~ If YES, enter delivery address below: 7". '- SeRver to addressee onl 3. Servic~e ~ified Mail 0 Express Mail o Registered IJI..Aet:nrn Receipt for Merchandise o Insured Mail 0 C.O.D. '3Cb 4. Restricted Delivery? (Extra Fee) ltI.-,c<> 2. Article Number (Copy from S8 ice labelj . L 'i~~ '-t:J~ ~I PS Form 3811., ,July 1999 Domestic Return Receipt 102595-GG-M-1789 + 'I' '" ~1~!!GiI~~lil!"llMI~~ij~~:~'~ . -'--I ,~"Hl'" ',' ""[ ,'l,~ '-;'- '~~"j_f.' .,.;" ~-, - r" " , .