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Home My WebLink About99-03843Lam.` J .u ti .a 00 1 TIMOTHY.I. RITCHIE : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION - LAW KIMBERLY A. RITCHIE, :NO. 99 - jgy3 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 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 (717) 249-3166 TIMOTHY J. RITCHIE, Plaintiff V. KIMBERLY A. RITCHIE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99 - 31-11-3 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, Timothy J. Ritchie, is an adult individual currently residing at 107 Mooreland Avenue, Mount Holly Springs, Cumberland County, Pennsylvania. 2. Defendant, Kimberly A. Ritchie, is an adult individual currently residing at 1115 Pheasant Drive North, Carlisle, Cumberland County, Pennsylvania, since 1997. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. n I-V 4. The parties were married on December 29, 1984 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage between the parties is irretrievable 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. Plaintiff has chosen to not request counseling, WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant pursuant to 23 P.S. Section 3301(c) of the Divorce Code. Dated: Respe ly submi ed, homas S. Diehl, Esquire Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX VERIFICATION I verify that the statements made in this Divorce 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. TI OT . ITCHIE '? 1' •?? ?. a ppp? pt ' _ ? ? ?\ _' _' ( _ ?J ?? ?, V 1\ M '? TIMOTHY J. RITCHIE, Plaintiff V. KIMBERLY A. RITCHIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 99-3843 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this a 9 day of I C 1999, comes Thomas S. Diehl, Esquire, Attorney for Plaintiff, Timothy J. Ritchie, and states that he personally mailed a certified copy of a Complaint In Divorce to the Defendant, Kimberly A. Ritchie, 1115 Pheasant Drive North, Carlisle, Cumberland County, Pennsylvania by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on June 26, 1999. Thomas S. Diehl, Esqui Attorney for Plaintiff 401 East Louther Street Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249- 2407 - FAX I Z 339 067 203 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. nn nnl nm in, Inlwrnalinnal Mail /.Saw rwuar<wl h m m 8 M 0 a Sent to KIMBERLY A RITCHIE heels Ni'M PHEASANT DRIVE N Post Uric eleb a ISLE PA 1701 Postage $ "'t' Carolled Fee f/v Special Delivery Fen_ _ Resldmed 6ry Fee nelum c s S Who e e Be 0 to Dmd, ass Y '0 TONAL se Post*rk ?. pS r SENDER: • Complete (lama I and/or 2 fo' additional services I also wish to receive the . • Complete Items 3, 4e, end 4b. • Print your name and address an the reverse of thi f following saN(Ces (Ifor an s orm so th card to YYou. at we can return this extra fee): R • Attach Ihls form to the front of It's mailplece, or on the back 11 ermll. W space does not 11ssl:aa'as-tW SS „ • rite Wewm Receipt noqueslM'on the maortlece below It's arlcle number 2• Restricted Delivery • The Return Receipt will show to whom the aricfo was d li e vered and the dale denemed. 0 3. Article Adtlressa to: 4a. Article Number ° P! KIMBERLY A RITCHIE Z 339 067 203 M 4b. Service Type 1115 PHEASANT DRIVE NORTH M Registered ? Certified o CARLISLE PA 17013 ? Express Mail ? Insured W ? Ralurn Recetpll'MerchandI a ? COD m 5. Recei 6. Signs 'o X/te T PS Form 7. Date of Deliv ry ? 4P me) 6. Addressee' Address (Only it requested ,Y and lee is paid) or Agenry- DecelnHer 1994 Io2W, ao If o:2, DOiReSft Return - ?... `- r <.- ,': ??: ??: c.J ,, , v! _" ?. .... ?