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Home My WebLink About07-3801. 1 •` 0 ?ft Alea P. Montgomery Plaintiff V. Michael M. Giles Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 3 f'ro / 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 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, 1 Courthouse Square, 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Alea P. Montgomery Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. Michael M. Giles Defendant NO. 07- 3 ?D ( CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is , who currently resides at ?PiY ? ? S1 JUG , RIOT L n Cumberland County, Pennsylvania. 2. Defendant is I //ekwJ IeS , who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on at 5. The marriage is irretrievably broken, and the parties separated on o?ab? 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. o ? 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. (012/ 7 ?--? Date' 1, , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. (.Q lT l Date. Pl ti ' ,Pro S/e Ks d by: arcus A. McKnight, III, Esq Irwin & McKnight Law Offic( 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 t1 ? c j r N n A C-n cry Alea P. Montgomery IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 3"1 CIVIL TERM Michael M. Giles Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Alea P. Montgomery, Plaintiff, to proceed in forma au eris. I, Marcus McKnight, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Marcus ?. McKn'g?I, Esq. Attorney for Plai Irwin & McKnight Law Offices 60 W. Pomfret Street Carlisle, PA 17013 (717) 249-2353 Date: June 25, 2007 -Tj c? -?, Po to -V r: rn a -o c n Alea P. Montgomery IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.-04- o -7 3"11 CIVIL TERM Michael M. Giles Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Alea P. Montgomery, Plaintiff, to proceed in forma au ris. I, Tabetha A. Tanner, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Tabetha A. Tannerney, Esquire Attorney for Plaintiff Tanner Law Offices 1300 Market St., Suite / Q Lemoyne, PA 17043 (717) 731-8114 ,Y ICE OF RLUK W)T 2089 V 18 AM IQ: 12 € ENNSYLVANtA Alea P. Montgomery Plaintiff V. Michael M. Giles Defendant To The Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.4)9-- 0- 390/ CIVIL TERM IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT Please reinstate the Complaint filed in the above-captioned case. Respectfully Submitted, C??P?'??"?tAN1? r: P Alea P. Montgomery IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 69= 61- 380! CIVIL TERM Michael M. Giles Defendant IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on It" da)-2 and continued to live separate and apart for a period of two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. I, Oita 1ty?-?'0,?-7??pr , verify that the statements made in this Affidavit are true and correct t he be of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. Date OF ff PROTHONOTARY 1009 NOV 18 AN 10: 12 CUM itJ OUN 1 PENNSYLVANIA IL Alea P. Montgomery Plaintiff V. Michael M. Giles Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. M_ 07- 30 CIvIL. TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ? (i) The parties to this action have not lived separate and apart for a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. ? (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. 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: Michael M. Giles NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. OF THE P 2009 NOV 18 AM 10= 12 '-,(DUNTY PENNSYLVANIA