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Home My WebLink About99-05083h .; .y 'a '` r ': .;;r ?a ? l ,;;: r, ?' Ol uJ?' C; r r. o °i \? ry l'? a Q 0 (D v H r' c m w 7 d o ° N O ? r O < O W M C N Kayer and Brown A Professional Corporation Liberty Loft * 4 E. Liberty Avenue • Carlisle, PA 17013 (717)243.7922 .II?I'FRFY SCO'T'T DAVIS, Plaintiff vs. TERFSSA DAVIS, Defendant IN '1'111: COURT OF COMMON PLEAS 01 CUMBERLAND COUNTY, PENNSYLVANIA CIVIL AC'T'ION - LAW NO. 99-S*6R3 CIVIL, TERM 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. 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 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. PENNSYLVANIA LAWYER REFERRAL SERVICE PENNSYLVANIA BAR ASSOCIATION 100 SOUTH STREET, PO BOX 186 HARRISBURG, PA 17108 (800) 692-7375 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J. Kayer, Esquire 4 East Liberty Avenue Carlisle, PA 17013 (717) 243-7922 JEFFREY SCOTT DAVIS, Plaintiff VS. TERESSA DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.99- 56of3 CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE COMES NOW, Plaintiff JEFFREY SCOTT DAVIS, through her attorney, James J. Kayer, Esquire and avers as follows: COUNT 1- DIVORCE 1. Plaintiff is JEFFREY SCOTT DAVIS, an adult individual who resides at 70 Big Spring Terrace, Newville, Carlisle, Cumberland County, Pennsylvania 17241. 2. Defendant is TERESSA DAVIS, an adult individual who resides at 24 South Grant Street, Apt. 3, Gaflisle, Waynesboro, Pennsylvania 17268. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 4, 1998 in Green Springs, Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce filed in this matter. 6. Plaintiff and Defendant are not members of the United States Armed Forces. 7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of the Divorce Code. 8. 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 the court to enter a decree of divorce. Respectfully submitted, Loft Carlisle, P? jl7013 (717) 243-7922 VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. 1 have read the statements made in this document and to the extent that it is based upon information which 1 have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. 1 understand that false statements herein are made subject to the penalties of 18 pA. C.S. § 4904, relating to unsworn falsification to authorities. Date: -" // Q 1999 // Kayer, and.Brown A Professional Corporation Liberty Loft • 4 E, Libe;Sy Avenue • Carilsle, PA.17013 (717) 243-7922 JEFFREY SCOTT DAVIS, Plaintiff VS. TERESSA DAVIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 5083 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, JEFFREY SCOTT DAVIS, and that he did serve a true and correct copy of the Notice to Defend and Complaint in Divorce that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, TERESSA DAVIS, on AUGUST 31, 1999. The return receipt is attached hereto. Swom to and subscribed before me stns Is' day of Septem er, 999. N ublic NOTARIAL SEAL DENISE PINAMC'? T;. Notary Public Carlisle Borough, u: ^.?ndand County My Commission Expimc. rtuv 20. 2000 SENDER: w.x?at oc". •Compme Mama t eWa s-, w •rpnplala kerns J, aa, and 4b. f •pmsyour wdadd wthem aft&lormwlMly mrgtw oN to Mooch b on hoot d IM mYIpl.., or on tlw bock H slop d. M 96m t ci 3 I also wish to revs tlu fotiowlny services (tor an extra fee): 1. O Addreseea's Addrss? 2. ®-Kdstrkted Delivery consult poamlesterforfes. 145 chi 'Registered 13 0909111 Express Mall ? haired .. Retum Reralot for wrdattdse O DOD Ise Is Paid) 3 Flinn 3811, December 10259&97-8-0179 r^, L,1 _ _ Lf. 1 v. r Qm s v A y r o m • N 1 m C d ?5 r o y m r7 N O O f0 l=D 7 N J ., , Vs;fl'i.