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Home My WebLink About08-4679Jeannie Siegfried, Plaintiff V. Eugene Siegfried, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 08- 9G -) q 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 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 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 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Jeannie Siegfried, Plaintiff vi. Eugene Siegfried, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 08- `/G 79 CIVIL TERM DIVORCE COMPLAINT WITH EQUITABLE DISTRIBUTION COUNT The plaintiff, Jeannie Siegfried, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and equitable distribution: COUNT ONE DIVORCE UNDER 23 Pa C S %,3301(c) AND 3301(d) OF THE DIVORCE CODE Plaintiff is Jeannie Siegfried, who currently resides at 116 North Fayette Street, Shippensburg, Cumberland County, PA 17257, since on or about February 1, 2007. 2. Defendant is Eugene Siegfried, who currently resides at 74 Cortland Circle, Shippensburg, Franklin County PA 17257, since on or about August 1, 1996 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 7, 1988 in Mechanicsburg, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since approximately February 1, 2007. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II EQUITABLE DISTRIBUTION 9. Plaintiff repeats and realleges paragraphs one through eight. 10. Plaintiff and Defendant have acquired property during their marriage that is subject to distribution under the divorce code. WHEREFORE, Plaintiff requests the court to enter a decree dividing the property equitably between the parties and such relief as the court deems just. DATE Respectfully Submitted, I IiAEL LIGH O Certified Legal Intern ANNE M-ACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date &q-c?b Plaintiff N ?T V cr_s' ', r 1 - - ...ra. Cx.) l i Z_" Jeannie Siegfried, Plaintiff V. Eugene Siegfried, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 08- 4c.7 9 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Jeannie Siegfried, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 847tb Res ect lly s Ti ed, MICHAEL LIGHTFOOT Certified Legal Intern ANRE ALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ('} +v ? n ' ; ? ?- -? r`rE d_? ._ _. ? _-; .. -. t".4`,, 1 C: l ? Cal •-C Jeannie Siegfried, Plaintiff V. Eugene Siegfried, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 08 - 4679 CIVIL TERM PRAECIPE TO WITHDRAW DIVORCE COMPLAINT To the Prothonotary: Please withdraw the Divorce Complaint filed on August 4, 2008 in the above captioned matter. ?'? 16Y Da & Michael Lightfoot Certified Legal Intern D-FO A&-- AMEGAN4SMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C'f A..a °?' ??_} ., _ - ?. ? i f.. . . . ! ._?-. dY.. G:, , i. _. .?.. --• f'?l '• - , , t ? ..;:?