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HomeMy WebLinkAbout00-07064 ='"~=~~d,~~""~"--~"='" '0'" ,..'. ~ '''^'",,', ""'-"'~ '" "ii GENE R. WEIAND, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : CIVIL ACTION - LAW BUFFIE D. WEIAND, . : No. f)()O() ~ '::fDl./-( 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 of your children. 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 Prothonotary's Office, 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 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, PA 17013 (717) 249-3166 ~~'w~" -,~. ~ ' ~ ~ ~'="-, '. .,;_ii' ." ... ._'~ GENE R. WEIAND, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff . '. v. : CIVIL ACTION - LAW BUFFIE D. WEIAND, fi. ., -, A,,~ ; No. 0-0 - 7D (,. Y cWi.-t ~.. Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, GENE R. WEIAND, by and through his attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, BUFFIE D. WEIAND, upon the grounds hereinafter set forth: 1. Plaintiff is GENE R. WEIAND, an adult individual residing at 530 Fairway Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is BUFFIE D. WEIAND, an adult individual residing at 530 Fairway Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months previous to the filingofthis Complaint. - -., ~ o.~_~<~ ",__..",,', .,=<",'1,-""",~-"" ;<"""'''~b>''''''.'' _~~'V_, ,,__~ 4. The Plaintiff and Defendant were married on July 24,1999, in York Springs, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of United States of America. 7. The Defendant is not a member of the Armed Services of the United States. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that he may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the grounds on which the action is based are: (a.) That Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome; or (b.) That Defendant has committed adultery; or (c.) That the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. 2 '''_r ...' ^ "'~ '-, , ,,'-<!,. >''''~.",'j,,!ill.~'.", ,"""',"'" _","'L;,,'_L.~.'" .; ~I~n'" WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree In Divorce dissolving the marriage between the parties. Respectfully submitted, L~ CONSTANCE P. BRUNT, ESQUIRE Supreme Court LD. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff 3 ~~ ,~ - ,. ~--, -'''~-'" ~.- - - - -.".' . VERIFICATION I verify that the statements made in the foregoing Complaint In Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. !}4904, relating to unsworn falsification to authorities. DATED: to11t(60 ~1\'~Lj GENE R. WEIAND, Plaintiff ." - '{.-~ ~" '.-" , ~ -~-"";C;' -~6."~ - _ ". ;,,< 'h'; ~:.- ,L"~ ,_ ,. -, '"t 'E " f '" . GENE R. WEIAND, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW BUFFIE D. WEIAND, : No. 2000-7064 ITefendant : IN DIVORCE AFFIDAVIT OF SERVICE I, an agent or employee of Priority One Messenger Service, do hereby certify that on r1a t 3 ,2000, I did serve on Defendant, BUFFIE D. WEIAND, a certified copy of the Complaint For Divorce filed in the above-captioned matter, by personally delivering it to her at ~;'/J 3' g.m. at her residence at 530 Fairway Drive, Camp Hill, Pennsylvania, 17011. ~X:~ J "^ "- '''1W.li4' ..... ~ GENE R. WEIAND, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff . ' . v. : CIVIL ACTION - LAW BUFFIE D. WEIAND, : No. 2000-7064 : Defendant : IN DIVORCE PRAECIPE TO: Curtis R. Long, Prothonotary Please mark as withdrawn and discontinued the Complaint In Divorce filed in the above-captioned matter on October 13, 2000, on behalf of Plaintiff, GENE R. WEIAND. Respectfully submitted, /tI/J II j;dJ CONSTANCE P. BRUNT, ESQUIRE Supreme Court LD. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff