HomeMy WebLinkAbout07-4593DAWN M. MERRIS,
Plaintiff
v.
KEVIN T. MERRIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
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 Courthouse, 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 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 South Bedford Street
Carlisle, PA 17013-3302
Tele.~phone: (717) 249-3166
0\div\MBRRIS,DA W N-3 301(c)complaint
DAWN M. MERRIS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN T. MERRIS, CIVIL ACTION -LAW
Defendant IN DIVORCE
COMPLAINT
1. The Plaintiff in this action is DAWN M. MERRIS, an adult individual, who currently resides
at 14 Greenway Drive, Mechanicsburg, Pennsylvania 17055.
2. The Defendant in this action is KEVIN T. MERRIS, an adult individual, who currently
resides at 407 Penn Ayr Road, Camp Hill, Pennsylvania 17011.
3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage on May 21, 1994, in
Mechanicsburg, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in
this or any other jurisdiction.
6. The Plaintiff avers as the grounds upon which this action is based is that the marriage
between the parties hereto is irretrievably broken.
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7. The Plaintiff avers that two (2) children have been born of this marriage, Cameron Evan
Merris (age 9) and Brooke Mackenzie Merris (age 6).
8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the
right to request that the court require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of 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 P.C.S. §4904, relating to unsworn falsification
to authorities.
Date: ~~' 2 _6
DAWN M. RRI
STONE LaFAVER &~SHEKLETSKI
~~~
By
Su me Court #(y0~51
14 Bridge S eet .O. Box E
New Cum rl d, PA 17070
Telenho e 7-774-7435
for Plaintiff
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fl\div\MERRIS,D W AN-affofservice
DAWN M. MERRIS,
Plaintiff
v.
KEVIN T. MERRIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-4593 Civil Term
CIVIL ACTION -LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify
that I served the Complaint in Divorce in the above-captioned matter on the defendant, Kevin T. Merris,
at 407 Penn Ayr Road, Camp Hill, Pennsylvania 17011, by United States certified mail, postage prepaid,
restricted delivery, on August 6, 2007, as evidenced by the attached
SWORN TO AND SUBSCRIBED
before me this ?~ day of
2007.
~---~
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COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
KATHLEEN KEIM, Notary Public
New Cumberland Boro., Cumberland Co.
My Commission Expires Dec. 5, 2010
return receipts.
~! ~~. Postal Service
`CERTIFIED MAIL RECEIPT
(Domestic Mai! Only; No Insurance Coverage Provided)
For delivery information visit our website at www.usps.com,.,
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~ Postage
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Cerdfied Fee
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~ Retum Receipt Fee
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Restricted Delivery Fee
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~ Street, Apt No.;
~ or PO Box No. O
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^ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
^ Prirtt your name and address on the reverse
ao that we can return the card to you.
^ Attach this card to the back of the mailpiece,
or on the front if space permits.
A. Sign~a re
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1. le Addressed to:
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B. Received by (Printed Name) Cb. Dat/e bf DaNrery
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D. Is delivery address different from Rem 17 ^ Yes
If YES, enter delivery address below: ^ No
3. ce Type
Certified Mall ^ MaG
^ Registered Q Return Receipt for MericArldlw
^ Insured Mall ^ C.O.D.
4. Restricted DelNeryT (Extra Fee) Yea
2. Article Number
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PS Form 3811, February 2'004. Dtxttestic Return Receipt to2satsa¢ <'
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F: \FI LES\Clients\ 12731 \ 12731.1. Prae l
Creazed: 9/20/04 0:06PM
Revised: 10/29/07 1 L46AM
Hubert X. Gilroy, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 29943
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
DAWN M. MERRIS,
Plaintiff
v.
KEVIN T. MERRIS,
Defendant
IN THE COURT OF COMMON PLEAS OF
COUNTY, PENNSYLVANIA
N0.2007-4593
CIVIL ACTION -LAW
JURY TRIAL DEMANDED
PRAECIPE
To The Prothonotary of Cumberland County:
Please enter the appearance of Hubert X. Gilroy, Esquire, as attorney for Defendant, Kevin T. Merris,
in the above case.
Dated: October~~ , 2007
10 East High eet
Martson Deardor Williams Otto Gilroy & Faller
Hubert X. Gilroy, u
Carlisle, PA 17013
(717) 243-3341
ID #29943
Attorney for Defendant
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