Loading...
HomeMy WebLinkAbout03-4916DEBORAH A. THORNTON, Plaintiff, VS. MICHAEL A. THORNTON, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. O3 - 4ql[ 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 judgrnent 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, Cumberland County Courthouse, 1 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 ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, TO GET LEGAL HELP SHOULD CONTACT: Cumberland County Lawyer Referral Service 2 Liberty Avenue, Carlisle, Pennsylvania 1-(800)-990-9108 COYNE & COYNE, P.C. (717) 737-0464 Pa.. Supreme Ct. No. 53788 Attorney for Plaintiff DEBORAH A. THORNTON, Plaintiff, VS. MICHAEL A. THORNTON, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.~3..~Igl& CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE NOW COMES the Plaintiff, DEBORAH A. THORNTON, by her attorney, Lisa Marie Coync, Esquire and files this Complaint In Divorce and avers the following in support thereof: 1. The Plaintiff, DEBORAH A. THORNTON, is an adult individual residing at 135 S. Enola Drive, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant, MICHAEL A. THORNTON, is an adult individual residing at 3730 Simpson Road, Harrisburg, Dauphin County, Pennsylvania. 3. The Plaintiff and Defendant are sui juris and have been bona fide residents in the Commonwealth for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 19, 1970, at Enola, Cumberland County, Pennsylvania and separated on August 21, 2003. The Defendant is not a member of the Armed Services of the United States or any of its 6. 7. There have been no prior actions of divorce or for annulment between the parties. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Cotwt require the parties to participate in counseling. 2 COUNT I --REQUEST FOR A NO FAULT DIVORCE 8. The prior paragraphs of this Complaint are incorporated by reference. 9. The marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests the Court enter a Decree in Divorce, pursuant to Section 3301(c) or Section 3301(d), as may be appropriate. COUNT 1I - EQUITABLE DISTRIBUTION The prior paragraphs of this Complaint are incorporated by reference. Plaintiff and Defendant have acquired property, both real and personal, and debt during 10. 11. their marriage. 12. Plaintiff and Defendant have been unable to agree as to the equitable division of said property and debt. WItEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debt pursuant to the Divorce Code. Respectfully submitted: COY/gE & COYNE, P.C. By: //~LISA MARIE COY]NE, Esquire // 3901 Market Streey // Camp Hill, PA 17011-4227 // (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff V~CATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for tmswom falsification to authorities under 18 Pa. C.S.A. §4904. Dated: DEBORAH A. THORNTON, Plaintiff, VS. MICHAEL A. THORNTON, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-4916 CIVIL TERM : IN DIVORCE PROOF OF ORIGINAL SERVICE OF COMPLAINT I, LISA MARIE COYNE, ESQUIRE, hereby certify that I have, on September 19, 2003, caused a tree and correct copy of the Complaint for Divorce and Custody to be served upon the Defendant named below by way of certified first class mail, restricted delivery, postage prepaid, return receipt requested: Michael Thornton 3730 Simpson Street Harrisburg, PA 17111-2070 Dated: '~ 22 --0'~ COYNE & COYNE, P.C. ( uT^co , squir¢ L..3~01 Market: S~eet Camp Hill, PA 170114227 (717) 737-04~ Pa. S. Ct. No. 53788 Attorn~ for Plaint~ · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. a Pdnt your name and address on the reverse so that we can return the card to you. · Attach this card to the beck of the mailpiece, or on the front if space permits. 1, Article Addressecr to: 2. Article Numbe~ (Transfer from eervice'label) , Ps Form 3811, August 2001 -- [] Agent ct- q-o DELIVERY I ~111.,~?~. 3. Service Type 7002 2410 OD07 8508 9973 3 7002 2t 1007 8508 9973