HomeMy WebLinkAbout03-1638F:\FILES\DATAF1LE\General~)ocuments\ 10819- l.dcomJtde
Created: 4/9/03 8:23:43 AM
Revised: 4/9/03 2:0:57 PM
10819.1
KAREN E. THOMAS,
Plaintiff
V.
ANDREW J. THOMAS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- }63~' CWIL 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 with your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary, First Floor, Cumberland County Court House, Carlisle, Pennsylvania 17013.
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
KAREN E. THOMAS, · IN THE COURT OF COMMON PLEAS OF
Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA
v. · NO. 03- /~7 CIVIL TERM
ANDREW J. THOMAS, ·
Defendant ' IN DIVORCE
COMPLAINT UNDER
SECTION 3301{c) OF THE DIVORCE CODE
1. Plaintiff is Karen E. Thomas who currently resides at 11 McBride Avenue, Carlisle,
Cumberland County, Pennsylvania, since 1997.
2. Defendant is Andrew J. Thomas, who currently resides at 111 Amy Drive, Carlisle,
Cumberland County, Pennsylvania, since January of 2003.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on June 24, 1989, in Mechanicsburg,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff requests the Court to enter a Decree of Divorce.
MARTSON DEARDORFF WILLIAMS & OTTO
Edward L. Schorpp, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
VERIFICATION
The foregoing Divorce Complaint is based upon information which has been gathered bymy
counsel in the preparation of the lawsuit. The language of the document is that of counsel and not
my own. I have read the 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 content of the document is that of counsel, I have relied upon counsel in making
this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
Karen E. Thomas
F:\FILES~DATAFILE\General'ff)ocuments\ 10819-1 .dcom
KAREN E. THOMAS,
Plaintiff
Vo
ANDREW J. THOMAS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COLrNTY, PENNSYLVANIA
:
: NO. 03-1638 CIVILTERM
: IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
:SS.
COUNTY OF CUMBERLAND )
I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Andrew
J. Thomas at 11 l Amy Drive, Carlisle, PA 17013 on April 10, 2003, by certified mail, restricted
delivery, return receipt requested.
Attached is the Post Office return receipt signed "Andrew J. Thomas" and dated April 15, 2003.
Sworn to and subscribed
before me this 16~ day of
April, 2003.
-~otary Publi~ ~t
NOTARIAL SF. AL
RICIA D ECKENROAD, Notary Public
Carlisle ~'xo., Cumberland Count/
~.~;ion _ Expire~ Oq].. 23, 2004..,