HomeMy WebLinkAbout99-07159`1 D'
-MMENNEM 1-11'u
SUSAN K. KOURY IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
VS. No.
.Y
PETER M. KOURY, SR.
Defendant CIVIL ACTION -- LAW
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 PROPERTY OR OTHER RIGHTS IMPORTANT TO YOUINCLUDING CUSTODY OR V SITATION OF YOUR MONEY OR
CHILDREN.
GROUND WHEN THE INDIGNITIES MARRIAGE, YOU MAYREQUESST MARRIAGE COUN ELING. A LIST OF MARK AGE COUN COUNSELORS BREAKDOWN OF THE
AVAILABLE IN THE OFFICE OFTHE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, I
COURTHOUSE SQUARE, CARLISLE, PA 17013.
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
ANYOFTHEM.
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 LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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SUSAN K. KOURY IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
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7/S 4 OtL'7tu
vs. No. 9q,
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PETER M. KOURY, SR. I
Defendant CIVIL ACTION -- LAW
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COMPLAINT IN DIVORCE
AND COMES NOW, SUSAN K. KOURY, by her attorney, Timothy J. Colgan, Esq., and files
the following Complaint in Divorce:
1. Plaintiff, SUSAN K. KOURY, resides at an undisclosed address in Cumberland County,
Pennsylvania 17055 since October 1999.
2. Defendant PETER M. KOURY, SR. resides at 219 Paxson Avenue, Schuylkill Haven,
Schuylkill County, Pennsylvania 17972.
3. SUSAN K. KOURY, Plaintiff, and PETER M. KOURY, SR., Defendant, have been 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 July 26, 1980 at Cressona, Schuylkill County,
Pennsylvania.
5. There has been one prior action for divorce between the parties which was voluntarily
discontinued by the Plaintiff in that action, Susan K. Koury.
6. Neither party is presently a member of the Armed Forces on active duty.
7. The parties have not entered into a written agreement as to alimony, counsel fees, costs, and
property division.
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. Being so advised, Plaintiff does not
request that the Court require the parties to participate in counseling prior to a Divorce Decree being
issued by the Court.
9.The cause of action and sections of Divorce Code under which Plaintiff is proceeding are:
(a) §3301(a)(6). Defendant has offered such indignities to Plaintiff, the
innocent and injured spouse, as to render her condition intolerable and life
burdensome.
(b) §3301(c). The marriage of the parties is irretrievably broken.
10. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests the Court enter an Order dissolving the marriage between
the Plaintiff and Defendant.
Dated: 11- z z 1J9
Respectfully submitted,
Ic1 w ? 7N
Timothy ]. gaKE genre
WILEY, LENOX & COLGAN, P.C.
1 South Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
I.D.#77944
VERIFICATION
1, SUSAN K. KOURY, verify that the statements made in this document are true and correct to
the best of my knowledge, information, and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities.
Date: pj ) q q q ,1IA dAAA, K. /? Ar,0
SUSAN K. KOURY
Plaintiff
c-.
1,, f^ .J
SUSAN K. KOURY
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
No. 99-7159
PETER M. KOURY, SR.
Defendant
CIVIL ACTION -- LAW
ACCEPTANCE OF SERVICE
1, PETER M. KOURY, SR., Defendant in the above-captioned matter, have accepted
service of the Complaint as of this, the day of h<c? fe- , 1999.
ETER M. KOURY, SR.
Address
City, State Zip
SUSAN K. KOURY
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
VS.
No. 99-7159
PETER M. KOURY, SR.
Defendant
CIVIL ACTION - LAW
To the Prothonotary:
Please withdraw this action without prejudice (upon payment of your costs only).
Respectfully submitted,
Dated: -?
Timothy J/CUlgw, wire
WILEY, LENOX & COLGAN, P.C.
1 South Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
I.D.#77944
I, Timothy J. Colgan, Esquire hereby certify that I am this day serving a copy of the
foregoing document upon the person(s) and in the manner indicated below, which service
satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of
same in the United States mail, first-class, postage prepaid, as follows:
Peter M. Kourg Sr.
219 Paxson Avenue
Schuylkill Haven, PA 17972
WILEY, LENOX & COLGAN, P.C.
Date: /"17-op By:
Timothy J. C re
Supreme Court I.D. #77944
1 South Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
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