HomeMy WebLinkAbout03-1692Kellie Leigh Bowes
10 Hat-John Drive
Carlisle, PA 17013
(717) 240-0197
Vo
Josephus Penderanda Langaman
602B Fisher Ferry Street
Thomasville, NC 27360
(336) 472-3543
IN TIlE COURT OF COMMON PLEAS OF
Cumberland COUNTY, PENNSYLVANIA
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court for
X._..~¥OlT~A~
Support
Division of property
Temporary Alimony
Costs
Custody and visitation
Alimony
Attorney Fees
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must
d~ke prompt acqoxt You are warned that i.f you f~l to do so, the ~ may proceed without you and a decree of
vorce or armulmeat may be entered against yon by the court A judgment may also be enler~ against you for
any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to
you, including custody or visitation of your utm
When the grounds 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
Cumberland.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER~o FEES OR
EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO
CLAIM ANY OF THElVL
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.
LAWYER REFERENCE SERVICE
ONE READING CENTER
PHILIDELPHIA, PENNSYLVANIA
TELEPHONE: (215) 238-1701
Kellie Leigh Bowes
10 I-lm'-Jolm Drive
Carlisle, PA 17013
(717) 240-0197
IN THE COURT OF COMMON PLEAS OF
Cumberland COUNTY, PENNSYLVANIA
Josephus Penderanda Langaman
602B Fisher Ferry Street
Thomasville, NC 27360
(336) 472-3543
COMPLAINT IN DIVORCE
COUNT I
REQUEST FOR DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is Kellie Leigh Bowes who currently resides at 10 lq_ar-John Drive, Carlisle, PA 17013,
County of Cmnberland, Commonwealth of Pennsylvania~
2. Defendant is Josephus Penderanda Langaman, who currently resides at 602B Fisher Ferry Street,
Thomasville, NC 27360, County of Davidson, Commonwealth of North Carolina.
3. Kellie Leigh Bowes has been a bona fide resident of thc Commonwealth of Pennsylvania for a
period of more than six (6) months immediately preceding the filing of this Complaint.
4. The parties were married on March 16, 2001, at Guliford County, North Carolina. Attached hereto
and marked Exhibit "A" is the certificate of marriage evidencing said marriage.
5. Neither plaintiff nor defendant is in the military or naval service of the United States or it allies
within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its
amendments.
6. All marital property has been previously divided.
7. There have been no prior actions for divorce or for annulmem between the parties except __
8. The defendant has been advised of thc availability of counseling and the right to request that the
Court require the parties to participate in Counseling.
9. The marriage of the parties is irrevocably broken.
10. After 90 days have elapsed from the date of thc filing of this Complaint, Plaimiffintends to file an
affidavit consenting to a divorce.
Page lof2
WHEREFORE, when plaintiff f-des and affidavit consenting to a divorce after 90 days have elapsed
from thc date of filing of this Complainl, Plaintiff respectfully requests that a decree of divorce be entered
pursuam to Section 3301(c) of thc Divorce Code dissolving the marriage between Plaintiff and Defendant.
K¢lli¢ Leigh Bowes, Plaintiff
I verify that the statements made in this Complaint arc true and correct. I undexstand that false statements
herein are made subject to the penalties of 18 Pa., C.S. Section 4904, relating to unswom falsifications to
authorities.
Page 2 of 2
Kellie Leigh Bowes
10 Har-Jolm Drive
Carlisle, PA 17013
(717) 240-0197
Josephus Pendetanda La~gam~
602B Fisher Ferry Street
Thomasville, NC 27360
(336) 472-3543
IN THE COURT OF COMMON PLEAS OF
Cumberland COUNTY, PENNSYLVANIA
NO.
AFFIDAVIT UNDER SECTION 3301(d) (1) OF THE DIVORCE CODE
Kellie Leigh Bowes, being duly sworn according to Law, deposes and says that:
The PlaintiffKellie Leigh Bowes, and the Defendant Josephus Penderanda Langaman~ have lived
separate and apart since November 9, 2001, a period of more than 2 years immediately preceding the filing
of this action.
The mamage between the parties is irretrievably broken and any attempt at reconciliation would be
· llie' 'gh Bowes, Plaintiff
Sworn to ~ subscn~oed
Kellie Leigh Bowes
10 Hat-John Drive
Carlisle, PA 17013
(717) 240-0197
Vo
Josephus Pendetanda Langaman
602B Fisher Ferry Street
Thomasville, NC 27360
(336) 472-3543
IN THE COURT OF COMMON PLEAS OF
Cumberland COUNTY, PENNSYLVANIA
NO.
COUNSELING NOTICE
~ ,of Pe__nn~y_ ~l.v, an?,r~ .uires that y?u be notified of the availability of counseling where
sought unaer any oI me IOllowing grolmos
Section 3301 (a) (6) -Indignities
Section 3301 (c) - Irretrievable breakdown-
Mmual Consent
Section 3301 (d) - Ixretrievable breakdown- Two/Three year
separation
A list of qualified professionals is available for in~spection in
The office of the Prothonotary at: Cumb~hand
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
FAMILY DIVISION
Inre: The Marriage of:
KELLIE LEIGH BOWE~
Plainti~
NO.
JOSEPHUS PENDERANDA LANGAMAN
AFFIDAVIT OF NON-MILITARY SERVICE
Kellie Leigh Bowes, being duly sworn according to Law, deposes and says that she knows by her own
~e~ ~?_ _kn_o_w,!edg. e. and therefof, e_a~v~rs~tl~t,d~endant Josephus Pen .de.~an~ _d~ Lan~ is 30 years of age;
l~ cmp~oyea oy ~/A/IM ~g~,,/i } at ~ ~./"/.~00
oa~dthet~a~olh~iis .n, ot i~. ~.e. mili~m~..,se~rv?eAo.f the United States or its allies, or otherwise within the provisions
o mc ooJmers ana ~anors; ~nai Keuct Act of Cong~ss of 1940 and its amendments.
State of Pennsylvania
County of Cumberland
that she is the person described in the above docmnent and that she signed the above document in my
prese~, v.~ ~ the inform~on contained in the foregoing documem is true and correct on
peri.n.m, rmOWlO~jl~Ta~,~ltltj8~ that the docmnent was signed as a free and voluntary act for the
My C~ltm~§Sion e~