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HomeMy WebLinkAbout03-1678JEFFREY LEWIS WALDEN, PLAINTIFF vs. REBECCA MARIE WALDEN, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. O3-/~78' CIVIL TERM : CIVIL ACTION. LAW : ACTION FOR 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. When 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 in the Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387. 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 PA 17013 (717) 249-3166 1-800-990-9108 JEFFREY LEWIS WALDEN, PLAINTIFF VS. REBECCA MARIE WALDEN, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. O-~ '~ ! t,, '7 ~CIVIL TERM : : CIVIL ACTION - LAW : ACTION FOR DIVORCE COMPLAINT FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, JEFFREY LEWIS WALDEN, making the following consolidated complaint in divorce for divorce. 1. Plaintiff is JEFFREY LEWIS WALDEN, an adult individual, who currently resides at 912 Bonny Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055, and has resided in Cumberland County for over five (5) years. 2. Defendant is REBECCA MARIE WALDEN, an adult individual, who currently resides at 912 Bonny Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 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. The Plaintiff and Defendant were lawfully married on April 24, 1993. 5. There have been no prior actions of divorce or for annulment between the parties except this Complaint filed for divorce. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the court require the parties to participate in counseling. Plaintiff has chosen not to engage in, or to request any counseling. 8. Neither Plaintiff nor Defendant was a member of the United States Military Services. 9. Plaintiff and Defendant have no children from their marriage. COUNT I - REQUEST FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 10. thereto. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference 11. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to the divorce. Plaintiff believes Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of filing of this Complaint, Plaintiff, JEFFREY LEWIS WALDEN requests the court to enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. COUNT II - REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE 12. thereto. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference 13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff, JEFFREY LEWIS WALDEN, respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. Dated: April 11, 2003 Respectfully submitted, C~~ W~lden 912 Bonny Lane Mechanicsburg PA 17055 (717) 697-5848