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HomeMy WebLinkAbout07-6241THOMAS SNYDER, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. :NO: ~07- ~ayi C~~~i Tom, CIVIL ACTION -LAW MARIA F. FIGUEROA-SNYDER, Defendant. IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the cleans 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 in divorce or annulment maybe entered against you by the Court. A judgment may also be entered against you for another 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, DNISION 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 (717) 249-3166 THOMAS SNYDER, Plaintiff, v. MARIA E. FIGUEROA-SNYDER, Defendant. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Thomas Snyder, by and through his attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Complaint in Divorce: 1. The Plaintiff, Thomas Snyder, is an adult individual currently residing at 122 Peach Orchazd Road, Newville, Cumberland County, Pennsylvania. 2. The Defendant, Maria E. Figueroa-Snyder, is an adult individual currently residing at 122 Peach Orchazd Road, Newville, Cumberland County, Pennsylvania 3. Plaintiff and Defendant have both been bona. fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on August 24, 2003, in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant aze members of the Armed Forces of the United States or any of its Allies. 7. Plaintiff has been advised of the availability of counseling and that he has the right to request that the Court require both parties to participate in counseling. 8. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 9. There were two (2) children born out unto the parties, Drakonus Figueroa Snyder, born May 2, 2004, and Estrella Snyder, born February 25, 2001. 10. Plaintiff avers as grounds on which this action is based are: A. that the marriage is irretrievably broken pursuant to §3301(c) of the Divorce Code; 10. Plaintiff avers as grounds on which this action is based are: A. that the marriage is irretrievably broken pursuant to §3301(c) of the Divorce Code; B. that as of September, 2009, the parties will have lived separate and apart for a period of at least two (2) continuous years pursuant to §3301(d) of the Divorce Code; and C, that Defendant has offered such indignities to the person of the Plaintiff as to render the condition of the Plaintiff intolerable and life burdensome pursuant to §3301(a) of the Divorce Code. WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. COUNT I EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 above are incorporated herein by reference and made apart hereof. 12. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Section 401 of the Divorce Code of 1980. COUNT II CUSTODY 13. Paragraphs 1 through 12 above are incorporated herein by reference and made a part hereof. 14. Plaintiff and Defendant are the natural parents of two (2) children, Drakonus Figueroa Snyder, born May 2, 2004, and Estrella Snyder, born February 25, 2001. 15. The Plaintiff is the natural father of the aforementioned children, and the Defendant is the natural mother of the aforementioned children. 16. The one child was born during marriage, and the first child was born outside of wedlock, before the marriage. 17. Plaintiff knows of no other party seeking custody or partial custody of the children. 18. Since the birth of each of the two children, they have resided with the Plaintiff and the Defendant at the address contained in paragraph 1 above. 19. Plaintiff believes and therefore avers that it is in the best interests in the children to grant primary custody of the children unto the Plaintiff in that he is able to best provide the day to day care for the children. 20. Plaintiff is also concerned because the Defendant has indicated that she is considering moving to the state of South Carolina to be with another man. WHEREFORE, Plaintiff prays this Court A. Enter a Decree in Divorce; B. Equitably distribute all property, both real and personal, owned by the parties; C. Grant primary physical custody unto the Plaintiff; and D. Grant such further relief as the Court may deem equitable and just. Respectfully submitted, Mancke, Wagner, Spreha & McQuillan Attorneys for Plaintiff Date: D D 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. ~~ ~ .~~ DATE: ~ O " l 2 - O ~-, -{~*, 3 r ~ -~- ~k 6- C> ~; O K„ +n~j • f -~ Q r-r, ~~ .Q ~ t! `J ._ ~- I f17 -~ 1 ~ :~~ ~ ..~: -<