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RONALD L. RHOADES, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND 60., PENNSYLVANIA
V. NO.
CATHY A. RHOADF&fendant
CIVIL 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 in 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.
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 TARE 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.
Court Administrator
Cumberland County Court House
1 Courthouse Square - Fourth Floor
Carlisle, PA 17013-3387
(717) 240-6200
Z 11
Joseph J. Dfx
on, Esquire
Attorney for Plaintiff
RONALD L. RHOADES, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNA.
V. CIVIL ACTION-LAW
CATHY A. RHOADES, NO. 9 9• q3
f Cc?i ?
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, this et Day of Tv /Y 1999, comes the Plaintiff,
Ronald L. Rhoades, by and t rough his attorney, Joseph J. Dixon, Esquire who respectfully
avers as follows:
The Plaintiff is Ronald L. Rhoades, an adult individual who resides at 30 South 1711
Street, Camp Hill, Cumberland County, Pennsylvania 17011.
2.
3.
4.
5.
6.
7.
R.
9.
The Defendant is Cathy A. Rhoades, an adult individual who resides at 2008 Princeton
Avenue, Camp Hill, Pennsylvania 17011.
Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months prior to the filing of this Complaint.
The Plaintiff and Defendant were married on August 4, 1973 in Lock Haven,
Pennsylvania.
There are two (2) children born of this marriage; Shelby Lynn Rhoades, born August 6,
1974 and Brian Lynn Rhoades, born November 27, 1981.
The parties became separated on February 14, 1999.
There have been no prior actions in divorce or annulment between the parties.
The marriage is irretrievably broken with no possibility of reconciliation.
The Plaintiff is aware of the availability of marriage counseling and waives any
opportunity or rights he may have to seek marriage counseling.
WHEREFORE, the Plaintiff prays this Honorable Court enter a Decree in Divorce.
COUNTI
EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
10. The averments in averments 1 through 9 of this Complaint are incorporated herein by
reference thereof.
11. The parties hereto own and/or possess marital property and liabilities which is subject to
equitable distribution of marital property.
WHEREFORE, the Plaintiff prays this Honorable Court enter a Court Order equitably
distributing marital property.
Respectfully submitted,
By:
J. EP J. DIXON, ESQUIRE
4 TORNEY Y ID NO. 28290
126 STATE STREET
HARRISBURG, PA 17101
717-236-8515
ATTORNEY FOR PLAINTIFF
DATE:
VERIFICATION
I verify that the statements made in this t19 /A/
are true and correct. I understand that false
statements herein are made subject to the penalty of 18 Pa. C.S.
54904, relating to unsworn falsification to authorities.
DATED:] Ir f
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