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CRAIG STONE, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 49 - *ya/q1 '
BRENDA STONE, : CIVIL ACTION -LAW
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.
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, 1 Courthouse Square,
Carlisle, Pennsylvania 240-6100.
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.
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Carlisle, PA 17013
944440-62N 7- 1/17 -1214 41
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July 2), 1999
CRAIG STONE, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
BRENDA STONE, CIVIL ACTION -LAW
Defendant : IN DIVORCE
COMPLAINT UNDER SECTION 3301fc1
OF THE DIVORCE CODE
Plaintiff is CRAIG STONE, who has resided at 2786 Den Mil Road,
Lancaster, Lancaster County, Pennsylvania, for the last month.
2. Defendant is BRENDA STONE, who has resided at 1460 Lutztown Road,
Boiling Springs, Cumberland County, Pennsylvania, for the last four (4) years.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six (6) months immediately previous to the filing of this
Complaint.
4. Plaintiff and Defendant were married on October 3, 1982 in Lancaster,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
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6. Ne;f..
ci of the parties in this action is presently a member of the Armed
Forces.
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7. Plaintiff and Defendant are both citizens of the United States.
July D. IM
8. Plaintiff has been advised of the availability of marriage counseling and that
he may have the right to request the Court to require the parties to participate in such
counseling. Being so advised, Plaintiff does not request that the Court require the parties
to participate in counseling prior to a divorce decree being handed down by the Court.
9. Plaintiff avers that there are two children of the parties under the age of
eighteen (18) namely: Shawn Stone, born on January 13, 1985 and Jason Stone, born on
April 13, 1986.
COUNT I - DIVORCE
10. The Plaintiff avers that the grounds on which the action is based are as
follows:
(a) That the marriage is irretrievably broken.
(c) Plaintiff and Defendant will have been living separate and apart for a period
in excess of two (2) years;
COUNT II - EQUITABLE DISTRIBUTION
11. During the marriage, Plaintiff and Defendant have acquired various items of
marital property, both real and personal, which are subject to equitable distribution under
Chapter 35 of the Divorce Code.
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WHEREFORE, Plaintiff requests this Honorable Court:
a. Enter a decree of divorce;
MY 11, 19W
b. Equitably distribute all property, both personal and real, owned by the
parties;
c. Grant such further relief as the Court may deem equitable and just.
Respectfully Submitted,
Dated: July 23, 1999
Jay 1 Xdernfan, Esquire
Stip . I.D. #07047
200 orth Third Street
Twelfth Floor
P.O. Box 689
Harrisburg, PA 17108-0689
(717) 232-2103
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CRAIG STONE, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
BRENDA STONE, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
VERIFICATION
I, CRAIG STONE, hereby verify and state that the facts set forth in the foregoing
document are true and correct to the best of my information, knowledge and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.
§4904 relating to unsworn verification to authorities.
G
CRAI ONE
DATE:
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CRAIG V STONE : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff No. 99-4496 CIVIL'fERM
V.
CIVIL ACTION - LAW
BRENDA STONE : IN DIVORCE
Defendant
TO THE PROTHONOTARY:
Please enter the appearance of LUTHER E. MI SPAW, JR., Esquire, as counsel for
Defendant in the above captioned matter.
Respectfully submitted,
MILSPAW & BESHORE
Dated: kI J
V
Luther P."Milso , Jr., Esquire
126 Locust Street
P.O. Box 946
Harrisburg, PA 17108
(717) 236-0781
CRAIG V. STONE IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
No. 99-4496 CIVIL TERM
V.
CIVIL ACTION - LAW
BRENDA STONE
i IN DIVORCE
Defendant
The undersigned hereby certifies that, on August 5,
1999, a true and correct copy of the Entry of Appearance was
served on Defendants' attorney by U.S. mail, first class, postage
prepaid, and addressed as follows:
Jay R. Braderman, Esquire
COGNETTI & BRADERMAN
200 North Third Street
Twelfth Floor
P.O. Box 689
Harrisburg, PA 17108-0689
Date: August 5, 1999 MILSPAW & BESHORE
BY:
Elizabeth M.Gable, Legal Assistant
Attorneys for the Defendant
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