HomeMy WebLinkAbout07-4220
MICHAEL C. HIRST,
Plaintiff
vs.
MARTHA-LOUISE HIRST,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. (~ 7 ' ~ 1"~ Civil Term
ACTION 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.
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 South Bedford St.
Carlisle, Pa. 17013
(717) 249-3166
w
MICHAEL C. HIRST, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. O`~ ., y ~ ~ d Civil Term
MARTHA-LOUISE HIRST, ACTION IN DIVORCE
Defendant
COMPLAINT IN DIVORCE
1. Plaintiff is Michael C. Hirst, a competent adult individual, who has resided at 1820
Suncrest Drive, Carlisle, Cumberland County, Pennsylvania, since July 7, 2007.
2. Defendant is Martha-Louise Hirst, a competent adult individual, who has resided at
171 Cedar Lane, Carlisle, Cumberland County, Pennsylvania, 17013 since 2004.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on September 11, 1996 in Prince
George's County, Maryland.
5. There have been no prior actions of divorce or for annulment between the parties.
6. 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.
7. Plaintiff and Defendant have no children together.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of America or any of its allies.
10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
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.
Michael C. Hirst, Plaintiff
Respectfully submitted,
Date: ~ - /v
ne Adams, Esquire
I.D. No. 79465
64 South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
n
~`
W
(U~
W
`~3
W
(°4
1
O
bo-
~ ~~
-- ~; c~~
;
- ~,
' `n
~~,
` T
' :ey
~ ~~~
r
cx~ ~ .~
{( i
4?
?
~^
y
.. ~: j~~~
~ u
\i
MICHAEL C. HIRST, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 8~- ~/a;a,Q Civil Term
MARTHA-LOUISE HIRST, :ACTION IN DIVORCE
Defendant
AFFIDAVIT OF SERVICE
AND NOW, this August 10, 2007, I, Jane Adams, Esquire, hereby certify that
on July 30, 2007, a certified true copy of the NOTICE TO DEFEND and COMPLAINT IN
DIVORCE was served upon the following person, via certified mail, return receipt requested at
the following address:
^ Complete items 1, 2, and 3. Also complete a Signature
Martha L. Hirst item 4 if Restricted Delivery is desired. O Agent
^ Print your name and address on the reverse - O llddneeee
171 Cedar Lane so that we can return the card to you. q~ by (Prr ted Name) C. Date d E7rNwry
Carlisle
Pa. 17013 ^ Attach thito the back of the mailpiece,
, or on the space permits.
1. Article Addeessed to: D, Is delivery address d
If YES, enter delivery a 19 ^ llbs
ow: O No
`~ i ~~ V~w~ 3. Servke TYPe
'~ ~ ~ ~ ~~ ~~ ~ Certified Mail ^ F~cpress Mail
^ Registered D Retum Receipt for MerCfw~ee
^ Insured MeY ^ C.O.D.
4. Reshlcted DeNvrryT ~ Fee) 19 1'is
2. ARicleNumber 7DD7 D22D OD02 2529 3472
(flar+~rlrom servlcelabel)
f~S Form 3811, February 2004 Domestic Retum Receipt ia~-02a„~_t~ao
Respectfully Submitted:
e Adams, Esquire
.D. No. 79465
64 South Pitt Street
Carlisle, Pa. 17013
(717)245-8508
ATTORNEY FOR PLAINTIFF
~ ~
~; ~
-r~
'~ i:. s'
''`
`
-
.:
`~
~ -,-
`
'
~" ~
~ ' ~~
t.~
~> -~