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Jon Paul Sundell,
Plaintiff
V.
Angelique Renee Sundell,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. aY-5:2 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 ground for the 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 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 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.
Cumberland County Bar Association
2 I.,iberty Avenue
Carlisle, PA 17013
(717) 249-3166
Jon Paul Sundell,
Plaintiff
V.
Angelique Renee Sundell,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. e?9. 52 516 CIVIL TERM
IN DIVORCE
COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d)
OF THE DIVORCE CODE
AND NOW comes the Plaintiff Jon. Paul Sundell, by and through
his attorney, Richard C. Gaffney, Esquire, who files this
complaint in Divorce and in support thereof avers as follows:
1. Plaintiff is Jon Paul Sundell, who currently resides at
RR 2, Box 306, Winfield, Union County, PA, 17889, since November
1, 1998.
2. Defendant is Angelique Renee Sundell, who currently
resides at 3 William Penn Drive, Camp Hill, Cumberland County,
PA, 17011, since May 1, 1999.
3. Plaintiff and Defendant have been a bona fide residents
in the Commonwealth for at least six months immediately previous
to the filing of this Complaint.
4. The Plaintiff and Defendant were married on January
5,1994 in Dauphin County, Pennsylvania. The parties separated on
September 1,1998.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably 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.
8. Plaintiff requests the court to enter a decree of
divorce.
WHEREFORE, Plaintiff requests this Honorable Court to enter
a decree of divorce pursuant to 23 P.S. Section 3301 (c) or 23
P.S. Section 3301 (d).
Respectfully submitted,
Richard C. Gaffney, quire
Attorney for Plaintiff
Supreme Court I.D. No. 63313
P.O. Box 627
101 Front Street
Boiling Springs, PA 17007
Telephone: (717) 249-2525
Facsimile: (717) 249-5141
Jon Paul Sundell,
Plaintiff
V.
Angelique Renee Sundell,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL TERM
IN DIVORCE
Verification
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. Cons. Stat. Ann. Q 4904,
relating to unsworn falsification to authorities.
Date: 264W X99
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Jon Paul Sundell,
Plaintiff
V.
Angelique Renee Sundell,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. qq' S 2 S (O CIVIL TERM
IN DIVORCE
Certificate of Service
I, Richard C. Gaffney, Esquire, hereby certify that on the
211 ' day of Aug.jS? , 1999, I served a true and correct
copy of Plaintiff's Complaint in Divorce by Certified Mail,
Restricted to Address only, Return Receipt Requested and by
United States Mail, first class postage prepaid to the following
person:
Angelique Renee Sundell
3 William Penn Drive
Camp Hill PA, 17011
Date:
Richard C. Gaff , E re
Attorney for the Pla n iff
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