HomeMy WebLinkAbout00-08846
-"~,,"" ,,~~"~"' ~ .., ....
, .
~~
'~
~ . . .,
..
,
CRYSTAL L. PEFFER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V ANlA
; No. 0-0, ftif4G. ~ I~
vs.
DOUGLAS R. PEFFER,
Defendant
: ACTION 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.
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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
iLl'"
'"-~,,,l!O,~'
~.". .
"'
-
" "
.""
:,,'(
. .
CRYSTAL L. PEFFER,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
No. 0rJ- 8'8'4(,.~J~
DOUGLAS R. PEFFER,
Defendant
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Crystal R. Peffer, an individual sui juris, who resides at 135 Center St.,
Carlisle, Cumberland County, Pa. 17013.
2. Defendant is Douglas R. Peffer, an individual sui juris, who resides at 175 S. Orange
St., Carlisle, Cumberland County, Pa. 17013.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on November 4, 1995 in Las Vegas,
Nevada.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling.
7. Plaintiff and Defendant have two children together, namely, Emily Elaine Peffer, dob
12/25/93 and Chad William Peffer, dob 3/26/98.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces ofthe United States
of any of its allies.
C'l'~-- .
'" ",-,- "~.
I. '.~
~~- "......" -
~ ~iIllIeiIiIIi' ~~ u
"l~~k;
>.... ... .
10. The Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken; and/or
(b) That the Defendant has offered such indignities to the Plaintiff, the innocent
and injured spouse, as to render her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
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. ~4904 relating to unsworn
falsification to authorities.
Respectfully submitted,
Date: \~~o\%
J e Adams, Esquire
. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAlNTITF
-
i~~~~~liJi":h~:Il'ii;i('!:iM'$,'~~~"OO.!~'fj;~~Y:'-'iii#I~~:d"ri>~,:,'.-!,;;.~3izi-fcl:fr!Ao%i:'@~\JWti:l1lJ
~~
ti'
c>,
"
~.
",
,
c
<
--
, '"" ,v ~ 1l
~ <"
Il ~
~ _",,'~'" ,~ 0
--
~'~"-^
"Jj'ilt'r~L'~'J_'i!>;-""..1;,,,,,,
.-..
'.""
~
I
I
. . 4.'
n 0 C)
C CJ -n
:s'~ 0
-0 G', i'1
1'1'1 r~ ' C-, --
Z ~J
L::" C N ~~i~~J
~~t " CO
~c ,1...-1
..' )"T,
~~~ (5::D
.-,.0
r. O;n
::;::: 0=-1
-,-\ 5J
-< (::> -<
~
~
j
"
...
~ Vi ...J
~ ('\
~ (r,
ci
t
r
.
--"",_","",""<MM
"
.';..-." ,~" ,",,' ~ 'J ",'0 '
.
CRYSTAL L. PEFFER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V ANlA
vs.
: No. 00 - 8846 Civil Term
DOUGLAS R. PEFFER,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE OF
NOTICE TO DEFEND AND COMPLAINT.
AND NOW, this January 9, 2001, 1, Jane Adams, Esquire, hereby certify that
on January 2,2001, a true and correct copy of the NOnCE TO DEFEND and COMPLAINT
were served, via certified mail, restricted delivery, return receipt requested, addressed to:
Douglas Peffer
175 Orange Street
Carlisle, Pa. 17013
DEFENDANT
Respectfully Submitted:
~_ei?d.bU<<<1
. e Adams, Esquire
LD. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
~
"'l[";"'.;;";"^-";'l"~<J-~,;lj[;)i~",,~,slilliil\jj~mii!~ii;It.'~:ill~'lN1lill~~~~i!flWjiliil1ll~Wiiijjijj~lt1t"i!i~.Mijjj"
o
C
?
"1:1f:'Ci
fllj'f':
~t?
~C~
~~
=<
"
I.L
1
-
~"
C~}
'. !
-":'~1
:L'OO
c
"\
,~j ~;.~
, '
Sl
J
(5'R
--;
'c_
~
=<
:"'~1
.
, ; -< ~
"' ,,'_.'~
,~
. Complete items 1 , 2, and 3.1\1$0 complete'
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the fro'rft if space permits.
1. Article Addressed to:
A Received ,y (Please: Priht Cleatty)
C,ub tft S tl. Ptf\"t:IL
C. Signature
D,
o Agent
o Addressee
Dyes
o ~o
x
.D~1/~7 '2. frtJir
I 7 ~ J. On"ye. S J.-.
Cr I.I~fv-.- nOn
3'Ervice Type
ertified Mail 0 Express Mail
Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) Yes
2. Article Number (Copy from service labeQ ,
'7oq" 3"uO WI i' S7>I> I J UJ
PS Form 3811. July 1999 Domestic Return Receipt
102595-00.M.0952