HomeMy WebLinkAbout07-5811IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SERENA MARIE OWENS, CIVIL ACTION--LAW
Plaintiff IN DIVORCE
vs.
NO. D7 S~//
TIMOTHY WILLIAM OWENS, .
Defendant
NOTICE TO DEFEND AND CTrAIM 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, Cumberland County Courthouse,
Carlisle, Pennsylvania.
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.
Court Administrator
Cumberland County Courthouse
3 South Hanover St.
Carlisle, PA 17013
(717) 240-6200
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SERENA MARIE OWENS, CIVIL ACTION--LAW
Plaintiff IN DIVORCE
vs.
TIMOTHY WILLIAM OWENS,
Defendant
COMPLAINT UNDER SECTION 3301(c) OR 3301(d)
OF THE DOMESTIC RELATIONS CODE
AND NOW, comes Plaintiff, SERENA MARIE OWENS, by and
through her attorney, Fiona K. Line, and files the following
Complaint in Divorce, and in support thereof avers as follows:
1. Plaintiff is Serena Marie Owens, an adult :individual, who
currently resides at Regency South, 54 Monarch Drive, Carlisle,
Cumberland County, Pennsylvania 17015 since August 1, 2007.
2. Defendant is Timothy William Owens, an adult individual, who
currently resides at 1113 Sherwood Drive, Carlisle, Cumberland
County, Pennsylvania since September 14, 2007.
3. Plaintiff has been a bona fide resident in the Commonwealth
of Pennsylvania for at least six (6) months immediately preceding
the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 4, 2007
Carlisle, Pennsylvania.
,. ..
5. The Plaintiff and Defendant were separated on or about
September 14, 2007.
6. There have been no prior actions of divorce or for annulment
between the parties.
7. The Plaintiff and Defendant are not members of the armed
forces of the United States or any of its allies.
8. The Plaintiff avers that the marriage is irretrievably
broken.
9. Plaintiff has been advised of the availability of counseling
and that the Plaintiff may have the right to request that the
Court require the parties to participate in counseling. The
Plaintiff does not desire counseling.
10. Plaintiff requests the Court to enter a decree of divorce.
Dated: ,~'('~- ~ ~- Z~Q7
FION KIMBERL LINE
Attorney ID 65283
Attorney for Plaintiff
184 Virginia Ave.
Carlisle, PA 17013
(717) 991-1382
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
SERENA MARIE OWENS, CIVIL ACTION--LAW
Plaintiff IN~DIVORCE
vs. NO.
TIMOTHY WILLIAM OWENS,
Defendant
VERIFICATION
I verify that the statements made in the foregoing Complaint
in Divorce are true and correct to the best of my knowledge,
information and belief. This Verification is made only as to the
factual averments contained herein, and not to legal conclusions
and averments authorized by counsel in her capacity as attorney
for the party or parties hereto. I understand that false
statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904, relating to unsworn falsification to
authorities.
SERENA E OWENS
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