HomeMy WebLinkAbout03-1747PHYLLIS A. GODOY,
Plaintiff
v.
ANIBAL A. GODOY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: 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 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
irretr~ievable 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,
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
Telephone No. 1-800-990-9108 or 249-3166
Attorney for Plaintiff
TUCKER ARENSBERG & SWARTZ
P.O. Box 889
Harrisburg, PA 17108
(717) 234-4121
PHYLLIS A. GODOY,
Plaintiff
V.
ANIBAL A. GODOY,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:
: No.
:
: IN DIVORCE
COMPLAINT UNDER 3301(c)
OF THE DIVORCE CODE
1. Plaintiff is Phyllis A. Godoy, an adult individual
who is sui juris and resides at 323 A. Market Street, Lemoyne,
Cumberland County, Pennsylvania.
2. Defendant is Anibal A. Godoy, an adult individual
who is sui juris and resides at 2406 Franklin Road, Columbia,
Lancaster County, Pennsylvania. The present whereabouts of the
Defendant, Anibal A. Godoy, to the knowledge of the Plaintiff, is
the same.
3. Both Plaintiff and Defendant have been bona fide
residents in the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on
August 24, 1964, in Mexico City, Mexico.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. The Defendant is not a member of the Armed
Services of the United States or any of its Allies.
8. The Plaintiff avers that the ground on which the
action is based is that the marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the Court to enter a Decree:
A. Dissolving the marriage between Plaintiff and
Defendant; and
B. For such further relief as the Court may determine
equitable and just.
TUCKER ARENSBERG & SWARTZ
By:
No. 32551
111 N. Front Street
P.O. Box 889
Harrisburg, PA 17108
Attorneys for Plaintiff
I verify that the statements made in this Complaint are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unsworn falsification to authorities.
Godoy, Pla~t i f