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HomeMy WebLinkAbout07-3907TONYA L. ARMOLT, Plaintiff v. JEREMY Q. ARMOLT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- 3J~'d7 CIVIL 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 the Cumberland County Court House, Carlisle, Pennsylvania. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 TONYA L. ARMOLT, Plaintiff v. JEREMY Q. ARMOLT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- ~ `~~ 7 CIVIL ~~ IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Tonya L. Armolt, an adult individual who currently resides at 99 Pond Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Jeremy Q. Armolt, an adult individual who currently resides at 99 Pond Road, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 12, 2002, in Newville, Pennsylvania. DIVORCE 5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above. 6. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States. 8. Plaintiff avers that the marriage between the parties is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce. COUNT II-EQUITABLE DISTRIBUTION 10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above. 11. The parties have acquired real and personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. Date: U Respectfully submitted, RIEN, BARK SCHE Michael A. Scherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff VERIFICATIQN 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. C.S. § 4904, relating to unsworn falsification to authorities. _.~ ~-- ny . Armolt Date: ~~ (V~\~ `n~ ` V J ~ ~1 ~ '~ s ~,' °~ o (~ ~ ~ f~1 ~'S L} ~>>' ter, ~•~ , ~~J ~ ~ _ 7~ ~ r -n ~~t"; ~ ~ ~ I ~ ~ ~ ~ ' ? . .. - 1 - - la ~ -~ ~~, `~C: '~ ._° = _ t,PS