HomeMy WebLinkAbout03-5295WILLIAM D. YOCHUM, II,
Plaintiff
SHEILA RENEE MORGAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO.03' 5-~9~ CIVIL TERM
CIVILACTION - I~.W
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 counselc, rs 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,
LANYER'S FEES OR EXPENSES BEFORE A DIVORCE OR AIqNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM AN~f OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT ~IAVE A LANYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT W~ERE YOU CAIq GET
LEGAL HELP.
Cumberland Countv Bar Association
2 Libertv Avenue
Carlisle, PA 17013
TeleDhone: (717) 249-3166
fl\div\YOCHL~Mcomplaint
WILLIAM D. YOCHUM, II,
Plaintiff
SHEILA RENEE MORGAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03- b-;z ~ ~/
CIVIL ACTION LAW
IN DIVORCE
COMPLAINT
1. The Plaintiff in this action is WILLIAM D. YOCHUM, II, an
adult individual, who currently resides at 900 Brandt Avenue, New
Cumberland, Cu~)erland County, Pennsylvania 17070.
2. The Defendant in this action is SHEILA RENEE MORGAN,
individual, who currently resides at 312 Motley Street, Tenaha,
75975.
3. Both the Plaintiff has been a bona fide resident 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 March 25, 2002, in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction.
an adult
Texas
-1-
6 o
based is
broken.
7.
marriage.
8.
and that
The Plaintiff avers as the grounds upon which this action is
that the marriage between the parties hereto is irretrievably
The Plaintiff avers that no children have been born of this
The Plaintiff has been advised that counseling is available
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 di-
vorce.
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:
STONE LaFAVER~_EKLETSKI
Supr~ne ~u/t/~D #60251
414 Br~ge/Syreet, P.O. Box E
New C~%foe~l~nd, PA 17070
/tor~ for Plaintiff
WILLIAM D. YOCHUM, II,
Plaintiff
SHEILA RENEE MORGAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAi~IA
NO. 03-5295 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
)
COUNTY OF CUMBERLAND )
SS:
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, Sheila Renee
Morgan, at 1911 Peal Street, Nacogdoches, Texas 75965, by United
States Certified Mail, postage prepaid, restricted delivery, on
October 30, 2003, as evidenced by the attached Certified Mail return
receipts ~--~
SWORN TO AND SUi :C/~IBED //~ ~
F NOTARIAL SEAL l
~ ~ R. LUCI~'7, ~ta~ Public I
~ C~berl~d t~ro, Cumb~la~ Co. I