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HomeMy WebLinkAbout99-03339I Trudy Lynn Shuman, Plaintiff VS. Gary Allen Shuman, Defendant )IN THE COURT OF COMMON PLEAS )CUMBERLAND COUNTY, PENNSYLVANIA )CIVIL ACTION - LAW )No_gq - 3339 Sul? -le fRl 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 my be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these paters 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 Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Pennsylvania, Room No. 100. 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 YO 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) 243-3166 or(800)990-9108 Trudy Lynn Shuman, Plaintiff vs Gary Allen Shuman, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW j No. q9 - 3339 Cj-LuQ T rm COMPLAINT UNDER SECTION 3301U' OF THE DIVORCE CODE 1. Plaintiff is Trudy Lynn Shuman, who currently resides at 6225 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania, since January 29, 1999. 2. Defendant is Gary Allen Shuman, who currently resides at R. D. 1, Box 123F, Loysville, Perry County, Pennsylvania, since December 23, 1989. 3. Plaintiff, Trudy L. Shuman, has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on November 25, 1988, at Loysville, Perry County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the court to enter a decree of 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. Q? `??\URt(Y" Plaintiff Date: ??«q ?? ?n? 1, Trudy Lynn Shuman, certify that this is a true copy of the Complaint under Section 3301 O of the Divorce Code filed in the Court of Common Pleas of Cumberland County, Pennsylvania, on June 3, 1999. 1 i nl?'\\1fn(? Plaintiff Date: ?-. \\M ?nr? - CERTIFICATE OF SERVICE 1, Trudy Lynn Shuman, representing myself, state that, pursuant to Rule 412, Title 42, P.R.C.P. a copy of the Complaint under Section 3301 C of the Divorce Code was mailed by Certified Mail, Return Receipt requested to Defendant, Gary Allen Shuman on June 3, 1999, at the following address: Gary Allen Shuman R.D. 1, Box 123F L''o'ysville, PA 1770`47 BY: 6-?ti-u l?l ?Xl?t?loll Trudy L. Shuman, Plaintiff y ? v a cm ZD g CD Cf) q- Fo 1 -44 Lq ;' ?? cL I W rn a?