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HomeMy WebLinkAbout03-5668SHERRY K. BITTINGER, Plaintiff vs. G. CHRISTOPHER BITTINGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. o3- ? 7 CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND ~ 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 counselors is available in the Office of the Court Administrator, Cumberland County Courthouse, Hanover Street, 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 (717) 249-3166 SHERRY K. BITTINGER, Plaintiff G. CHRISTOPHER BITTINGER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION LAW : IN DIVORCE CO~iPLAINT IN DIVORCE NOW COMES Plaintiff, Sherry K. Bittinger, by her attorneys, Purcell, Krug &Haller, and avers as follows: COUNT I DIVORCE PURSUANT TO SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE currently resides at 223 Bosler Avenue, Pennsylvania. 2. Defendant is who currently resides County, Pennsylvania. Plaintiff is Sherry K. Bittinger, an adult individual who Lemoyne, Cumberland County, G. Christopher Bittinger, an adult individual at 591 South Front Street, Harrisburg, Dauphin Commonwealth of Pennsylvania for at least six prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on November Plaintiff and Defendant have been bona fide residents of the (6) months immediately in Camp Hill, Pennsylvania. 5. between 14, 1970, There have been no prior actions in divorce or annulment the parties. COUNT III EQUITABLE DISTRIBUTION 12. Plaintiff incorporates paragraphs 1 through 11 by reference hereto as though the same were set forth herein at length. 13. Plaintiff and Defendant possess various items of both real and personal property which are subject to equitable distribution by this Court. COUNT IV ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 14. Plaintiff incorporates paragraphs 1 through 13 by reference hereto as though the same were set forth herein at length. 15. Plaintiff does not have sufficient funds to support herself and pay counsel fees, costs and expenses incidental to the action. 16. Defendant is full and well able to pay Plaintiff alimony pendente lite, counsel fees and expenses incidental to this divorce action WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree: (a) Defendant; real, Dissolving the marriage between the Plaintiff and (b) Equitably distributing all property, both personal and owned by the parties; -3- (c) Ordering alimony pendente lite, in addition to counsel fees and expenses necessary for the Plaintiff to adequately prosecute this case; (d) Such further relief as the Court may deem equitable and just. Dated: PURCELL, KRUG Ho g, Esquire ID 6826 North Front Street Harrisburg, PA 17102 Telephone: {717)234-4178 Attorney for Plaintiff VERIFICATION I, Sherry K~ Bittinger facts contained in the foregoing · hereby verify that the Complaint in Divorce true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. unsworn falsification to authorities. are Section 4904, relating DATE: SHERRY K. BITTINGER, Plaintiff vs. G. CHRISTOPHER BITTINGER, Befendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-5668-Civil Term : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE Complaint Bittinger, acknowledge that James L. Goldsmith, Esquire, hereby accept service of the in Divorce on behalf of my client, G. Christopher Defendant in the above-captioned action, and I am authorized to do so.