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Home My WebLink About00-06957 SUSAN M. MOORE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0::) - &.9S1 GUll y~ MICHAEL A. MOORE, Defendant CIVIL ACTION - LAW 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 armuIment may be entered against you by the Court. A judgement 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 SUSAN M. MOORE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00- {.tj51 ~ I~ MICHAEL A. MOORE; Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is SUSAN M. MOORE, an aduIt individual residing at 202 Norman Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is MICHAEL A. MOORE, an adult individual residing at 8 Richland Lane, Apt. T8, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on June 15, 1991 in Cumberland County, Pennsylvania. 5. There are two (2) minor children born of this marriage: Daniel B. Moore, born April 6, 1992; and Cassidy M. Moore, born July 8, 1994. 6. The parties separated on April 24, 2000. 7. There have been no prior actions for divorce or armulment between the parties. ,--< , " "'.,e:,V;' ,-- """,, c-'.-':'::;-::;' '. :"~:'-:'t:-"7r:"::::L]:?:':\:. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with ~ 3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, SUSAN M. MOORE, prays this Honorable Court to enter a decree in divorce. Barbara Sump Ie-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Courtl.D. No. 32317 Dated: October 6, 2000 2 SUSAN M. MOORE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. MICHAEL A. MOORE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Datedll"J-. ,'7 , 2000 ~~ /1t 'fii& SUSAN M. MOORE I <,- o ~,', '~'> -, , 'r, 'C/,"'!., SUSAN M. MOORE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. MICHAEL A. MOORE, Defendant CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, SUSAN M. MOORE, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DatedccP .5 ,2000 ~A~~'~ 'AN . MOORE "-, , I:, ,~~-".",' ~'-'" .'" , , , '< 1-- ;'. '-:;~:- SUSAN M. MOORE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,' PENNSYLVANIA v. NO. 00-6957 MICHAEL A. MOORE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-SuIlivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7099 3220 0007 0903 6573, Return Receipt Requested, on the above- named Defendant, Michael A. Moore, on October 20,2000 at Defendant's last known address: 8 Richland Lane, Apt. T8, Camp Hill, PA 17011. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. Dated: October 23,2000 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff ,~ " ='<. ~ C) J~ ~, ' , ~:"':'-i. ,. .;l;..;_ ..l .__ _ ' (Jomcsilc Mali Only. No InsLl/ance Cove/age PJovlde ,) rTJ 1"-' :;:;J 'rTJ i-tJ IT" l:I CMlPHIU. Ptl17011 Postage $ tO~5$ Certified ,Fae 0070 05 I'- Return ReceIPt Faa C (Endorse-ment Required) C Restricted Dellvety Fee ' t::] (Endorsement RequIred) ~1 Postage & Fees . Pos1mark "". . l:I ru ~ i;ff!l&r~~~"j-~""''''''''''''-' ~ c.......;siB.iP-l.... ....,..........~;;4......~/T........................ $ 0.20 1011812000 T t."I; 1. .,d1or 2 for additional services. ;; ~. 4a, and 4b, : lI!, - Ii' ftRlB ~d address on the reverse of this form 80 that we can return this ,I -':~ thi'sUiorm to"the fr:~'of the mallplece, or on,the back if space does not 18 perm". ~ II "Write-Return Receipt Requested- on the mailplece below the article number. .. _The Retum Receipt will show to whom the article was delivered and the date , S '" ~elivered. I 3. Articl. Addressed to:', . .trI('. rL\'~ A. rLoore. "ll~ KJvhbnJ l-Ane, Ap+. t;~ ~, rv>O J.-l 'J.}{ P4 .. 'f /lO J} I alsowiSllolQ ~ ilia following~ (I'.ran .xtra f..): Ii 1. 0 Allilnessea's Adclr.... 1 2. .. RestJjcled Dalivery &l Consult postmaster for fee. I,' 4a. Article Number I t " a ! i "10"1 3~::lo 4b. Service Typ. o R.gistered 11 c.rtillP- o Expr.ss Mail 0 Insu.. o Return Receipt for M.rchandise 0 COD 7. Oat. of D.livsrY 10 8. Addr.sse.'s A ress (Only il requestefl and fee is peJd) I "~' ,!j; r !' EXHIBIT "A"