HomeMy WebLinkAbout03-5218Paul James Pifer,
Plaintiff
Elizabeth Marie Pifer,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03- 5~ / f-' CIVIL TERM
IN DIVORCE
NOTICE TO DEFEND
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 ofdivome 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 tights 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, High and Hanover Streets, Carlisle, PA.
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
2 Liberty Avenue
Carlisle, PA 17013
Phone: (717) 249-3166 or (800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For infbrmation about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the Court. You must attend the scheduled conference or hearing our office. All arrangements must
be made at least 72 hours prior to any heating or business before the Court. You must attend the
scheduled conference or hearing.
Paul Jmnes Pifer,
Plaintiff
Elizabeth Marie Pifer,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COU~NTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03- 5',;//~' CIVIL TERM
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is Paul James Pifer, who currently resides at 80 East Main Street, Newville,
Cumberland Cotmty, Pennsylvania 17241.
2. Defendant is Elizabeth Marie Pifer, who resides with her mother at c/o Barbara Kissick,
3377 Colfax Road, Hillsboro, Kentucky 41049.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months
immediately previous to filing of this Complaint and the Defendant was a bona fide resident of
Pennsylvania from 1993 to 2003 and moved to Kentucky on July 25, 2003.
4. Plaintiff and Defendant were married December 22, 2001 in Pensacola, Escambia Cotmty,
Florida.
5. There have been no prior actions of divorce or for mmulment between the parties hereto in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available, and that Plainliffmay have the
right to request that the Court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiffrespectfully requests this Honorable Court to enter a Decree in
Divorce and such other Orders as may be just and appropriate.
Date:
Respectfully submitted,
Mark F. Bayley, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 87663
Attorney for Plaintiff
VERIFICATION
1 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.
Paul James PifefT, PlaintiYf
Paul James Pifer,
Plaintiff
Elizabeth Marie Pifer,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CtVIL ACTION- LAW
NO. 03- :~l~? CIVIL TERM
IN DIVORCE
pRAECIPE TO WITHDRAW
TO THE PROTHONOTARY:
Please with&aw the Divorce Complaint in the above-captioned matter on behalf of Paul
James Pifer.
Date:
Respectfully submitted,
Mark F. Bayley, Es~ire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 87663
Attorney for Plaintiff
_CERTIFICATE OF SERVICF
I, Mark F. Bayley, Esquire, attorney for Paul James Pil~r, do hereby certify that I this day
served a copy of the Praecipe to Withdraw the Divorce Complaint upon the following by depositing
same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested,
postage paid, at Carlisle, Pennsylvania, addressed as follows:
Elizabeth Marie Pifer
80 East Main St.
Newville, PA 17241
Mark F. Bayley, Esquire
Attorney for Plainti;ff