HomeMy WebLinkAbout08-4644CHRISTA L. BOYER,
Plaintiff
VS.
MARTIN F. BOYER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08- 4&qq CIVIL TERM
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 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 at the Cumberland County Courthouse, 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, 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
32 SOUTH BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 249-3166
CHRISTA L. BOYER,
Plaintiff
vs.
MARTIN F. BOYER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08- 11611-Y CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, the Plaintiff, Christa L. Boyer, through her attorney, Dawn S. Sunday, Esquire
files this Complaint in Divorce based upon the following:
1. The Plaintiff is Christa L. Boyer, an adult individual, residing at 6 Franklin Hill Road,
Dillsburg, York County, Pennsylvania 17019.
2. The Defendant is Martin F. Boyer, an adult individual, residing at 6 Franklin Hill Road,
Dillsburg, York County, Pennsylvania 17019.
3. The Plaintiff and Defendant were married on June 5, 1987 in Cumberland County,
Pennsylvania.
4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
5. There has been a prior action for divorce between the parties in this jurisdiction which was
filed in 1996, but which was subsequently withdrawn or discontinued.
6. Neither of the parties in this action is presently a member of the Armed Forces on active
duty.
7. The basis for this action is the irretrievable breakdown of the parties' marriage.
8. The Plaintiff has been advised of the availability of marriage counseling and that
Plaintiff may have the right to request that the Court require the parties to participate
in counseling.
WHEREFORE, the Plaintiff respectfully requests that the Court enter a decree of divorce
under Section 3301(c) or 3301(d) of the Divorce Code.
Respectfully Submitted,
Dawn S. Sunday, Esquire
Counsel for Plaintiff
ID No. 41954
39 West Main Street
Mechanicsburg, PA 17055-6230
(717) 766-9622
VERIFICATION
I verify that the statements made in this Complaint 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.
7/311 t .
Date
Plaintiff
-TA
r i'!
as
CHRISTA L. BOYER IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
MARTIN F. BOYER 08-4644 IN DIVORCE
Defendant
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw the Complaint in Divorce filed by the Plaintiff on August 1, 2008
as proceedings were simultaneously initiated by the other parry in another jurisdiction.
Respectfully submitted,
Dawn S. Sunday
Attorney for Plaintiff
Attorney I.D. No. 41954
39 West Main Street
Mechanicsburg PA 17055
(717) 766-9622
r?
k t,?y cs5