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Home My WebLink About08-38970 Karen W. Miller, Esquire Attorney I.D. No. 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Christopher S. Chubb CHRISTOPHER S. CHUBB, Plaintiff, vs. JODI A. CHUBB, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. D p. 3 ?q 7 CtiL-d `?na ti 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 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 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, Cumberland County Court House, One 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. 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 32 South Bedford Street Carlisle, PA 17113 (717) 249-3166 Karen W. Miller, Esquire Attorney I.D. No. 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Christopher S. Chubb CHRISTOPHER S. CHUBB, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 0 9- 3 F 9 7 ?'t u Q JODI A. CHUBB, CIVIL ACTION - LAW Defendant. IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Christopher S. Chubb, an adult individual who resides at 495 Lucinda Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Jodi A. Chubb, an adult individual who resides at 922 Brandywine Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 25, 1994, in New Kingston, Cumberland County, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Defendant is not a member of the armed forces of the United States or any of its allies. 7. The Plaintiff avers that the marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. The Plaintiff does not desire counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Dater By: U),P- W , 'I IL K en W. Miller, squire Attorney I. D. # 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Plaintiff, Christopher S. Chubb 08094-001/131871 2 VERIFICATION 1, Christopher S. Chubb, verify that the averments made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Tate: ? 0?7 eP Christo er S. Chubb r" ? C` r_? ? o _ ?-= i'Tl p ?D o0 ? _ ? , ? 7? _. ?'aa i . F `„' ? ? k ? cJ? /`. '. .J Karen W. Miller, Esquire Attorney I.D. No. 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Christopher S. Chubb CHRISTOPHER S. CHUBB, Plaintiff, VS. JODI A. CHUBB, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. d 8. 3 S 9 (?,cu?? ?.- CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of Plaintiff, Christopher S. Chubb, with regard to the above-captioned matter. Respectfully submitted, CALDWELL & KEARNS Dated: Z_0,4 0A By: . Karen W. Miller Attorney I.D. #200037 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Plaintiff 08094-001/134956 Karen W. Miller, Esquire Attorney I.D. No. 200037 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Christopher S. Chubb CHRISTOPHER S. CHUBB, Plaintiff, VS. JODI A. CHUBB, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-3897 Civil Term CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint Under Section 3301(c) or 3301(d) of the Divorce Code that has been filed on July 1, 2008, with the Prothonotary of the Court of Common Pleas of Cumberland County. Date: o`lC>v (?t4'd JODI A. CHUBB 08094-0011134953 t7 ca Q V (David D. Buell (Prothonotary KirkS. Sohonage, ESQ Solicitor r< 0 1750 &nee X Simpson 15` Deputy Tyothonotary Irene E. Worrow 2nd Deputy (Prothonotary Office of the 1Trothonotary Cumberland County, Pennsylvania 08-3997 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 25T" 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 9 Carlisle, PA 17013 • (717) 240-6195 0 Ea.)C (717 240-6573