The URL can be used to link to this page

Home My WebLink About99-06313 1iAt r ? tly y.iir ' III Af ??Ci . y I 4 t y , (J. 4 m M1 am 4 r 13 < ;,, rn L ffv n ' €J SAA .d4 t ' . r? F y ° 1' f i t Y ? 1'p G k I ?Y 5?4.? f 'ytZtrM Y Mt ? G{ 1 4:Q 4 4? 4 s ?.. 5 e}. ( '} ?i? t y j DUI _ ?a 2 tw ?I.. ' v t Cll ? ? xd7? ?M. i I i 4?k . { of s? ? Z y 1 i ` ? t f#yr? ? 1 r / 6ti f ? 1 . vy . T d T 6 i f - ? 1 f he v Q f ,. A> s 1 r 1{ .-Ay 3 ? e ? ? V 1 ;f t ? , < - - t ? ? I r t f Ft1 vt t ;s SS. ?? t _ i L ?' Se 41 ? h ry k ` f r 4 4 c i i t3}r ??F•fi ? 4t ? ? i f3j3 ?, {tbs. I i t ' 4 Y. ++ r f 1 4? C ) A t} ?I V _ .l 3>, C!. fYx i !y N ?Ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ELAINE SARGEANT, Plaintiff v. i No. c1 _ 6,313 GLEN SARGEANT, s Defendant i IN DIVORCE NOTICE TO DEPEND 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, 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 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte on forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no as defiende, la corte tomara medidas y puede ertrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demanda. Usted puede perder dinero o sus propiedades o otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 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 disable 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY1 PENNSYLVANIA CIVIL ACTION - LAW ELAINE SARGEANTt i Plaintiff s s V. : GLEN SARGEANTI i Defendant s No. aq. G X13 e4'.;j -F&- IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE AND NOW comes the Plaintiff, Elaine Sargeant, by and through her attorney, Maryann Murphy, Esquire, who respectfully avers as follows: 1. Plaintiff is Elaine Sergeant who currently resides at 115 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Glen Sergeant who currently resides at 927 Woodbridge Drive, Enola, Cumberland County, Pennsylvania, 17025. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 7, 1980, in Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since January 8, 1997. 6. There have been no prior actions for divorce or for annulment between the parties. 7. Defendant is not a member of the Armed Services of the United States or any of its allies. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request that the Court require the parties to participate in 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. 10. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. il. Plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. 12. Plaintiff and Defendant are the owners of real estate, motor vehicles, bank accounts, insurance policies, pensions, retirement benefits and other persona]. property acquired during the marriage which is subject to equitable distribution by this Court. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. 14. Plaintiff requests this Court to equitably distribute the parties' marital property. m 15. Plaintiff hereby incorporates by reference all of the averments contained in Counts I and II of this Complaint. 16. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 17. Defendant is well able to pay support to Plaintiff. 18. Plaintiff requests this Court to grant her alimony pendente lite. 19. Plaintiff hereby incorporates by reference all the averments contained in Counts I, II and III of this Complaint. 20. Plaintiff does not have sufficient funds to pay the counsel fees, costs and expenses incidental to this action. 21. Defendant is well able to pay Plaintiff's counsel fees, costs and expenses incidental to this matter. 22. Plaintiff requests this Court to grant her counsel fees, costs and expenses incidental to this action. 23. Plaintiff hereby incorporates by reference all of the averments contained in Counts, I, II, III and IV of this Complaint. . 24. Plaintiff does not have a sufficient source of income or earning capacity at the present time to maintain the standard of living enjoyed by the parties during their marriage. 25. Defendant does have a sufficient source of income and earning capacity to aid Plaintiff in maintaining the standard of living enjoyed by the parties during their marriage. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; and b. equitably distributing all property owned by the parties hereto; and c. directing the Defendant to pay alimony pendente lite to Plaintiff; and d. directing the Defendant to pay Plaintiff's counsel fees and expenses incidental to this divorce action; and e. granting alimony to Plaint iff; and f. for such further relief as the Court may determine to be equitable and just. Respectfully Submitted: ,i Maryann rphy, Esquire Attorney for Plaintiff 845 Sir Thomas Court, Suite "A Harrisburg, PA 17109 (717) 540-8600 q Supreme Court I.D. 161900 to S' Dated: I 1'A O1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ELAINE SARGEANT, Plaintiff s s V. s s NO. GLEN SARGEANT, s Defendant s IN DIVORCE I, ELAINE SARGEANT, verify that the statements made in this Complaint Under Section 3301(d) of the Divorce Code are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ?CXli\(Not ELAINE SARGEANT Sworn and Sybscribed before me on this ?_ day of , 1999. otary Public NOTARUI KM IUTIM A. NOANTAK N*" Ni * lever POWs Tep.. ? QWOY. ?A MY Ca?Mon bppw &VM A 2M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ELAINE SARGEANT, Plaintiff V. NO. GLEN SARGEANT, Defendant IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counterclaim within twenty (20) days after this affidavit has been served on you or the allegations will be admitted. AFFIDAVIT OF PLAINTIFF UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on January 8, 1997 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, attorney's fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I UNDERSTAND THAT FALSE HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. \? ??: _? ?•3 { t?'?i?'??."t Date: ELAINE SARGEANT 1? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAN ELAINE SARGEANT, 2 Plaintiff s s V. f NO. GLEN SARGEANT, Defendant s IN DIVORCE I, Maryann Murphy, Esquire, do hereby certify that a true and correct copy of the within Complaint in Divorce under Section 3301(c) and the Affidavit of Plaintiff were mailed by first class U.S. mail, certified/ restricted delivery, postage pre-paid, addressed as follows: Glen Sargeant 927 Woodbridge Drive Enola, PA 17025 Date: q1Ac u Maryann urphy, Esqu r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY# PENNSYLVANIA CIVIL ACTION - LAW ELAINE SARGEANT, s Plaintiff t s V. s i NO. 99-6313 GLEN SARGEANT, _ Defendant s IN DIVORCE WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please withdraw the appearance of Maryann Murphy, Esquire on behalf of the Plaintiff in the above referenced matter. Respectfully Submitted, Dated: Z ct q _ IK Maryann rphy, Esquire/ 845 Sir homas Court, Suit 11A Harrisburg, PA 17109 (717) 540-8600 Id. No. 61900 Please enter the appearance of Marianne E. Rudebusch, Esquire on behalf of the Plaintiff in the above referenced matter. Respectfully Submitted, ?t ?4L Mar Gone E. Rudebusch, Esqu re 845 Sir Thomas Court, Suite 11B Harrisburg, PA 17109 (717) 657-0632 Id. No. 63522 ? C C'i t ??u a _