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HomeMy WebLinkAbout08-3256 Dayna A. Stimers Plaintiff V. Joshua W. Stimers Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.08- 3a5t,0 IN DIVORCE CIVIL TERM 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 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 W-- - -1 Dayna A. Stimers IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- 3-2,54 , CIVII. TERM Joshua W. Stimers Defendant IN DIVORCE - - ?l 1 ric 1J1 v UKC 1. Plaintiff is who currently resides at Cumberland County, Pennsylvania. 2. Defendant is ?? ? _, who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on u G / "/1, 1-1/1 S //) A'17 at 5. The marriage is irretrievably broken, and the parties separated on A . n- - 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date UU Plai ff, Pro Se i I, are true and correct to the best of my knowledge, information, and belief. verify that the statements made in this Complaint I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. 5-4-e9 Date: lain V,Prro. Se Assisted by: Thomas J. Williams, Esq. Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, PA 17013 (717) 243-1383 Cy ^,? `_ ?a n ?? ??a ,r ' 4 (_"_ W /".t ?: "1 1 .. ?..:? _ r : .. ?.. _ ..._ !_ . ` .. :;? ?i _,,,_ ?? ? Dayna A. Stimers IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 3,2510 CIVIL TERM V. Joshua W. Stimers IN DIVORCE Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: eris Kindly allow, Dayna A. Stimers, Plaintiff, to proceed in forma RAW - 1, I, Thomas J. Williams, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. ? '4La -? Thomas J. Will(arfis, Esquire Attorney for Plaintiff Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, PA 17013 (717) 243-3341 c'> ? '"" _ ?' - `? i i \ ? 2 t ? '.. } C • ..?+ ---_.. _i 'r,; ~ C? FL's -.? P:. FILES`Clients•5492 Mid Penn,5.192.7"Stimersi5492.'7.PRAREINSTATE Revised: S 15 08 10:7IAM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OT-FO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DAYNA A. STIMERS, Plaintiff V. JOSHUA W. STIMERS, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3256 CIVIL ACTION - LAW : IN DIVORCE PRAECIPE Please reinstate the Divorce Complaint. MARTSON LAW OFFICES By '--I k-61-A, W 1 e ., Thomas J. William/, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: August 15, 2008 .,: cz- a