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HomeMy WebLinkAbout00-05533 , ~':J;, DEBORAH L. WARNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA vs. : CIVIL DIVISION - LAW : IN DIVORCE CHRIS E. WARNER, Defendant . : NO. 06- S~.33 G~)L{~ 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 indignitites or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Court House, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 Connty Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 DEBORAH L. WARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERlAND COUNTY,PA vs. : CIVIL DIVISION - LAW : IN DIVORCE CHRIS E. WARNER, Defendant : No. COMPLAINT i :J , " COUNT I SECTION 3301(c) OF THE DIVORCE CODE OF 1980 :1 :1 1. Plaintiff is Deborah L. Warner, an adult individual who current mailing address ;j [, is P.O. Box 661, Dillsburg, Pennsylvania 17019. 2. Defendant is Chris E. Warner, an adult individual who currently resides at 1114 Ii .' 1,1 i1 r.1 'J d I': q !j fJ 1,1 [1 'j I:: '1 II :1 Karen Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 1, 1990. S. There have been no prior actions for divorce or annulment between the parties hereto. 6. Plaintiff avers that Defendant is not in any branch of the Armed Services. 7. This action is not collusive. 8. The marriage is irretreivably broken. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 1 ,. ~ < " "--'i.. -- " ' ~~-:;. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant from the bonds of matrimony. COUNT II SECTION 330Hd) OF THE DIVORCE CODE OF 1980 I 1 ;;1 i " H i , .j 'J ., ! I 10. Paragraphs one through nine of this Complaint are incorporated herein by reference as though set forth in full. 11. The parties are now living separate and apart; at the appropriate time Plaintiff will submit an affidavit alleging that the parties have lived separate and apart for at least 1 'j WHEREFORE, Plaintiff request your Honorable Court to enter a Decree in I ;< ,J , -j 1 "I two (2) years and that the marriage is irretreivably broken. Divorce, divorcing Plaintiff and Defendant from the bonds of matrimony. COUNT III -- ALIMONY 12. Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 13. Plaintiff lacks sufficient property to provide for her reasonable needs. 14. Plaintiff is unable to sufficiently support herself through appropriate employment. 15. Defendant has sufficient income and assets to provide continuing support for the Plaintiff. WHEREFORE, Plaintiff requests that the Court and/or Master enter an Order awarding alimony for Plaintiff against Defendant in an amount and for a period of time deemed appropriate upon consideration of all factors, pursuant to the Divorce Code. 2 - -~ ~ "^. "t&'>L COUNT IV - EOUlTABLE 16. Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 17. During the marriage Plaintiff and Defendant have acquired various items of marital property, which are subject to equitable distribution under the Divorce Code. 18. Plaintiff and Defendant have been unable to agree as to an equitable division of said property to the date of the filing of this complaint. WHEREFORE, Plaintiff requests that the Court and/or Master enter an order with regard to the equitable division of any marital property held by the parties and any other properties subject to equitable distribution under the Divorce Code. Respectfully submitted: Date:~J'~(Jj BRATIC & PORTKO -~ B~rO~G~\ :y~kO, Esquue 101 South U.S. Route 15 Dillsburg, P A 17019 (717) 432-9706 I.D. No. 34538 Attorney for Plaintiff 3 - ~ ' ~ " ~l'i~Jll(!!!n:t',', VERIFICATION I, DEBORAH L. WARNER, hereby acknowledge that I am plaintiff in the foregoing Divorce Complaint, that I have read the foregoing, and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa.C.S. Section 4904, Date: ~~Ioo falsification to authorities. /.~/~c:/~r DEBORAH L. WARNER relating to unsworn '. DEBORAH L. WARNER, Plaintiff "Is. CHRIS E. WARNER, Defendant . ~,~ 'liD <~.""e ~~~ - ~~;"" tr : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PA : CIVIL DIVISION - LAW : IN DIVORCE : NO. 2000-05533 Civil Term PRAECIPE TO DISCONTINUE To The Prothonotary: Please mark this action discontinued as to the Defendant, Chris E. Warner. Dated: April 26, 2001 c .\:~~ rO, ~1.~J~~~D Step~ Esquue J.D. #34538 101 South U.S. Route 15 DilIsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff .. -""'"-IBi1lllilU "~_ " ,'r ''''~'",,,,'_,,,,,.~, .<,. - ~tri"~~' m~~Jilii>];~llil~~~~mli!~~~~I.ItliljIiJi'1if t' ~r~ , " ~, ""~",,', " ,,'--". - ~, '." ""^^~ ",'. ~L I ----', IiiIiIIIiiI:lUI 'I , , ," d{ (") co c) c: ~n S :l: -oC-;:; ".. nltY, _..c .0" 2:-':; -,".:-::--' Z~. :~~~\ ~~ CfJ~-;-- 2"- .....c-:: "0 '. -n ~ "~-'-' ~o :::;: '::;~C) ..=0 ~ ~~rn :;p-c ':.:, ~ ?:Q \D -<;. .