HomeMy WebLinkAbout08-3768V
EDGAR VALENTINE,
PLAINTIFF
vs.
SHIRLEY JOAN VALENTINE,
DEFENDANT
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
: ~- 3 7(0~
NO. CIVIL TERM
CIVIL ACTION -LAW
ACTION FOR 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 procced
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.
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, One Courthouse Square, Carlisle, PA 17013-33$7.
IF YOU DO NOT FII,E A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
FEES OR E~ENSES 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. l(F' 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
1-800-990-9108
EDGAR VALENTINE,
PLAIIVTIFF
vs.
SHIRLEY JOAN VALENTINE,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
0 ~. 3 ~G ~
NO. CIVIL TERM
: CIVIL ACTION -LAW
ACTION FOR DIVORCE
AND NOW, comes the Plaintiff, EDGAR VALENTINE, by and through his counsel,
Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and makes the
following consolidated complaint in divorce for divorce.
1. Plaintiff is EDGAR VALENTINE, an adult individual, who currently resides at 5
Hoover Road, Carlisle, Cumberland County, Pennsylvania, 17015 and has resided in
Cumberland County for more than one (1) year.
2. Defendant is SHIItLEY JOAN VALENTINE, an adult individual, who currently
resides at 5 Hoover Road, Cazlisle, Cumberland County, Pennsylvania, 17015.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were lawfully married on August 27, 20()4.
5. There have been no prior actions of divorce or for annulment between the parties
except this Complaint filed for divorce.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling and of the right to
request the court require the parties to participate in counseling, plaintiff has chosen not to
engage in, or to request any counseling.
8. Neither Plaintiff nor Defendant have been members of the United States Military
Services.
9. There are no children from this marriage.
COUNT I - REQUEST FOR NO-FAULT DIVOR F
UNDER SECTION 3301(cl OF THE DIVORCE CODE
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference
thereto.
11. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff
intends to file an Affidavit consenting to the divorce, plaintiff believes Defendant may also file
such an affidavit.
AUNT II - REQUEST FOR EninT,q~LE DISTRIBUTION OF
t'Ai. PRnPFD~rv rTwm~n r*........._, _ ___ . _ _ _ __
12. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference
thereto.
13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties without regard to marital misconduct in such proportion as the Court
deems just after consideration ofall-relevant factors.
WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90)
days have elapsed from the date of filing of this Complaint, Plaintiff, EDGAR VALENTINE,
respectfully requests the court to enter a Decree of Divorce pursuant to Section 3301(c) of the
Divorce Code.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.C.
Dated: June~~,'2008
Counsel for Plai :,~'
PA I.D. #64998
4010 Gle
Mechanicsburg PA 17055
(717) 724-2278
VERIFICATION
The undersigned hereby verifies that the facts averred in the foregoing document are true
~d correct to the best of his knowledge, information, and belief. This verification is made
subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
DATED: ~' S~~iu~l ~S$' C ~ C/
EDGAR VALENTINE
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David D. Bueff
Prothonotary
1?frkS. Sohonage, ESQ,
Soficitor
&nee X Simpson
I" Deputy 1tothonotary
Irene E. Worrow
2"lneputy Prothonotary
Office of the (Prothonotary
Cum6erfand County, 1Pennsykania
68 -3noe CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P 230.2
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite 100 • Carfsle, TA 17013 • (717 240-6195 0 TaT (717 240-6573