HomeMy WebLinkAbout99-03694
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IN THE COURT OP COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBORAH A. TRAVERSIE.
Plaintiff
V.
CIVIL ACTION - LAW
IN DIVORCL
RICHARD A. TRAVERSIE, JR., NO. 99- 41 LI Cci,:Q 7-a-L, --
Defendant
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 arc 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 at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from the list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you
desire to pursue counseling, you must make your request for counseling within twenty (20) days of
the date on which you receive this notice. Failure to do so will constitute a waiver of your right to
request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OFTHEM.
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
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBORAH A. TRAVERSIE,
Plaintiff
V.
RICHARD A. TRAVERSIE, JR.,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NO. 99- 31,94 r?
COMPLAINT
ANDNOW,this 19rndayof TL,.a3
1999, comes Plaintiff, DEBORAH
A. TRAVERSIE, by and through her attorney, Michael J. Hanft, Esquire, and files the following
Complaint in Divorce, and in support thereof avers as follows:
Plaintiff is Deborah A. Traversie of 310 Fairview Street, Carlisle, Cumberland
County, Pennsylvania 17013.
2. Defendant is Richard A. Traversie, Jr., of 509 5" Avenue, NW, Minot, North Dakota
58703.
3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at
least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 8, 1994, in Mechanicsburg,
Cumberland 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.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce,
divorcing the Plaintiff from Defendant.
By
Michael J. Han' Es u' e
Attomey I. D. 0.57976
19 Brookwood Avenue, Suite 106
Carlisle, PA 17013
(717) 249-5373
Attorneys for Plaintiff
Date: T'j m2- l 9 i /191
VERIFICATION
I VERIFY that the statements set forth in the attached
document are true and correct to the best of my knowledge,
information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. Section 4904
relating to unsworn falsification to authorities.
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