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HomeMy WebLinkAbout08-3100 LAW OFFICES OF DILS &DILS DIANE M. DILS, ESQUIRE Attorney LD. No. 71873 1400 North Seeond Street, First Floor, Front Harrisburg, PA 17102 Telephone No. (717) 233-8743 Attorney for Debra K. Pfaff DEBRA K. PF.AFF IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. p$ - 3100 Civ-l KENNETH C. ,PFAFF, JR., :CIVIL ACTION -LAW Defendant IN 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 cause may proceed without you and a decree of divorce or annulment may be entered against you by 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage crunseling. A list of marriage counselors is available in the Prothonotary's Office, Cumberland Count-~ Courthouse, Carlisle, Cumberland County, Pennsylvania. IF YOU DO NOS' FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES ~~3EFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOI1 SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. . IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 LAW OFFICES OF DILS &DILS DIANE M. DILS, ESQUIRE Attorney I.D. No. 71873 1400 North Second Street, First Floor, Front Harrisburg, PA 17102 Telephone No. (717) 233-8743 Attorney for Debra K. Pfaff DEBRA K. PFAFF Plaintiff, vs. KENNETH C. PFAFF, JR., Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA -_._-~ . NO. ©F- 31~ ~ /.~ CIVIL ACTION -LAW IN COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Debra K. Pfaff, an adult individual whose current address is 5210 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, and whose social security number is 191-42-7737. 2. The Defendant, Kenneth C. Pfaff, Jr. an adult individual whose current address is 5210 Meadowbrook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, and whose social security number is 184-48-9583. 3. Plaintiff and Defendant were married on November 29, 1975 in Sherm~.~nstown, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allie-~. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There l.as been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. ,~ 9. There aye no minor children born of the marriage. 10. Plaintil~~ avers that the grounds on which this action ; is based are: (a) Tha~~, the marriage is irretrievably broken. WHERFwFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, BY: Harrisburg, PA (717) 232-9724 I.D. No. 71873 17102 1400 North Second Street r f VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DEBRA K. PFAFF Date: ~y 7, 2008 ~ ~ ~ ".~ ~~ @'3 , r; t ,"_ y ~ ~ ~j 00 ~ UI CIS ;':. ~ - '""~ CJl ~~ k"~'3 ` 0 ~ ~ ~ ~ ~~ ~ J 7 :~ ~ ~ ~ -~.