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Home My WebLink About99-03740?V tzw m i TAMMY A. CORL, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION - LAW STEPHEN R. CORL, :NO. 99 -3-74A)CIVIL TERM Defendant 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office 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 ONE. 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 TAMMY A. CORL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION - LAW STEPHEN R. CORL, :NO. 99 -37YP CIVIL TERM Defendant :IN DIVORCE COMPLAINT IN DIVORCE Plaintiff, Tammy A. Cori, is an adult individual currently residing at 415 Wren Court, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Stephen R. Cori, is an adult individual currently residing at 39 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania and have been for at least six months prior to the commencement of this action. Furthermore, Defendant has resided in Cumberland county continuously for at least six months prior to the commencement of this action. 4. The Parties were married on November 23, 1984 in Cumberland County, Pennsylvania. 5. In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievable broken. 6. There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 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 decree that the Plaintiff be divorced from the Defendant pursuant to 23 P.S. Section 3301(c). COUNT 11 8. Paragraphs I through 7 are incorporated herein by reference as if set forth in their full text. 9. Plaintiff and Defendant are the joint owners of certain real estate located at 39 Regency Woods North, Carlisle, Cumberland County, Pennsylvania. 10. Plaintiff and Defendant are the joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 11. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide their marital property and equitably apportion their debts. COUNT III 12. Paragraphs I through I I are incorporated herein by reference as if set forth in their full text. 13. Plaintiff is unable to provide for or afford her counsel fees, expenses, and costs during the pendency of this divorce action and through its resolution. 14. Plaintiff is without sufficient property and otherwise unable to financially support herself despite being employed. 15. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs as well as alimony and alimony pendente lite for Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay Plaintiffs counsel fees, expenses, and costs, as well as providing for payment of appropriate alimony and alimony pendent lite to Plaintiff. Dated: I 9 e( Respectfully submitted, c ti? omas S. Diehl, Esquire L Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407-FAX VERIFICATION t verify that the statements made in the foregoing document 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 falsifications to authorities DATF: TAMMY A. CORL I C? 0 J LO L?1 C? .44 CICII O U rL TAMMY A. CORL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. STEPHEN R. CORL, Defendant CIVIL ACTION LAW NO. 99-3740 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 7n1 day of 1999, comes Thomas S. Diehl, Esquire, Attorney for Plaintiff, Tammy A. Corl, and states that he personally mailed a certified copy of a Complaint In Divorce to the Defendant, Stephen R. Corl, at 39 Regency Woods North, Carlisle, Cumberland County, Pennsylvania by certified mail, return receipt requested. A copy of said receipt is attached hereto indicating service was made on June 30, 1999. Attorney for Plaintiff 401 East Louther Street Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249- 2407 - FAX Z 339 067 205 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not ,.. I., Inlern.linn.l u.ll /C.. r.... Sent to STEPHEN R CORL Street a I'VREGENCY WOODS N. Poet Ollic?s?LISLCE ePA 17013 Postage $ a j Certiliea Fee Spatial Dellv R ed ea N ? to ecal 8 fiv R elP sf s Fees m i SENDER: • Compete Henri t andlor 2W additional " Y • Camplels RaM 3.44. and 4b. • Pdnl WyUOUrvuM YM addreu on dice nvNM al tli Mm eo dW M till labNn 0Ya • AApesttaM?chFPNa 4+m to dw Vent of an mallplaw, or an dw bark a apace dolt not • w RKWd Roquaerod' on the m 1clace below tie aril :The Ralum Repalptwe Qq lowh=alaaNdewasdaevrdN dallwrel. 3. Article .4ddreseed to: G;'l, 6. Received By: (Print Name) (Print !dame) 17 6. Signatur (Adel e orAgeilt 1 also wish to receive the following services (for an extra lee): 1. ? Addressee's Address 2. ? Restricted Delivery consult postmaster for tee. 4a. Article N umber X e ?39 DG 7 ?def d 40. Servloe Type Registered ? Certified ? Express Malf ? Insured ? RaNm Receipt for MerdwMss ? COD 7. Date of y M 6 8. Addre e Add Mu (Only N l6quested 4p and lee Is Pell) oc:!= ?I A PS Form 3 11, December 1994 to2ate-re'som Domestic I C ??n iv f C2 Cy (.; 7 s G r]J y J ??, J _U lU ""1 4 G m ll-? r