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HomeMy WebLinkAbout03-5854Louise M Martin, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Jefferson L Martin, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, 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 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 at the 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Miller, Esquire for Plaintiff Louise M Martin, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. C?Sy l iu?l,? / Jefferson L Martin, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Louise M Martin, who currently resides at 6213 Edgeware Road, Mechanicsburg, Cumberland County, PA 17050. 2. Defendant is Jefferson L Martin who presently resides at 6213 Edgeware Road, Mechanicsburg, Cumberland County, PA 17050. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 9, 1989, in New York City, New York. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. The 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. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to: a) enter a decree dissolving the marriage between Plaintiff and Defendant; Respectfully Submitted, Miller Lipsitt LLC 01 By: James A M' er, Esquire Attorney f Plaintiff 2157 Ma et Street Camp ill, PA 17011 (7 737-6400 Louise M Martin, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. Jefferson L Martin, : CIVIL ACTION -LAW Defendant : IN DIVORCE VERIFICATION I verify that the statements made in this Divorce 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. DATE: ouise M Martin. Plaintiff ?J v J (J Y d9. 4 0 l cn C;. Y I r: ;*S tJt ?e -G o-Jn Louise M Martin, Plaintiff V. Jefferson L Martin, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5854 Civil Term CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT I, Jefferson L Martin, Defendant in the above captioned matter do hereby on the date indicated below accept service of the divorce complaint filed by Plaintiff, Louise M Martin, to the above term and docket. Date: Okt? ? -W,3 r Jef erson L Martin, Defendant n r ? nar %c' yam tv Renee K. Simpson Deputy Prothonotary Curtis R. Long prothonotary Df the protbonaarp Office Cumbertaub Ccuutp John E. Slike Solicitor 5 ?11 CIVIL TERM ORDER OF TERMINATION OF COURT CASES NOVEMBER 2007 AFTER MAILING E ?OV OF NOTICE AND NOW THIS 5Tx DAY OF CE WITH PA INTENTION TO PROCEED AND RECEIVING PREJUDICE- ACCORDAN CASE IS HEREBY TERMINATED WITH R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY Carlisle, Pennsylvania 17013 (717) 240-6195 • 'Fax (717) 240-6573 .,..o rm„rthouse Square Cam'