HomeMy WebLinkAbout03-5905Louis Joseph Michelsen,
Plaintiff
V.
Tracey Lynne Michelsen,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
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 of other rights important to you, including the 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 at the Office of the Prothonotary.
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
Louis Joseph Michelsen,
Plaintiff
V.
Tracey Lynne Michelsen,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. .~,~ ~5~,~/o~
CIVIL ACTION - LAW
COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, Louis Joseph Michelsen, pro se, and respectfully
represents as follows:
1. Plaintiff is Louis Joseph Michelsen, an adult individual, currently residing
at 819 Windsor Place Apt. 2, Mechanicsburg, Pa. 17055, Cumberland County,
Pennsylvania.
2. Defendant is Tracey Lynne Michelsen, an adult individual, currently
residing at 558 Beinhower Rd. Etters, Pa. 17319, York County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for a period of six months (6) immediately preceding the filing of the
Complaint.
4. Plaintiff and Defendant were married on August 22, 1998 in Harrisburg,
Dauphin County, Pa.
5. There have been no prior actions for divorce or for annulment between
the parties,
6. The Plaintiff and Defendant are both citizens of the United States of
America.
Count I - Divorce
7. The allegations of Paragraphs I through 6 are incorporated herein by
reference and made a part hereof.
8. This action is not brought through collusion between the Plaintiff and
Defendant, but in sincerity and truth for the reasons set forth within.
9. The marriage is irretrievably broken, and the parties are proceeding
under Section 3301 (c) and/or 3301 (d) of the Divorce Code.
10. Plaintiff has been advised that counseling is available and that Defendant
may have the right to request that the Court require the parties to participate in
counseling.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divome decree
dissolving the marriage between Plaintiff and Defendant.
Date:
I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the pt
relating to unsworn falsification to authoriti~
yI~INTIFF
Date: I~, k/ow ~
~lties of 18 Pa.C.S. Section 4904,