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HomeMy WebLinkAbout08-5889RICHARD C. SPAHR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. D2- 5891 CIVIL TERM PATTY K. SPAHR, Defendant : IN LAW - 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 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, First Floor, 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, 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 MO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RICHARD C. SPAHR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ; NO. CIVIL TERM PATTY K. SPAHR, Defendant : IN LAW - DIVORCE COMPLAINT IN DIVORCE AND NOW COMES the Plaintiff, RICHARD C. SPAHR, by and through his counsel, William L. Grubb, Esquire, and complains of the Defendant, PATTY K. SPAHR, as follows: COUNTI COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is RICHARD C. SPAHR, who currently resides at 4072 Seneca Avenue, Camp Hill, Lower Allen Township, Cumberland County, Pennsylvania, 17011. 2. Defendant is PATTY K. SPAHR, who currently resides at 4072 Seneca Avenue, Camp Hill, Lower Allen Township, Cumberland County, Pennsylvania, 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on August 19, 1991 at Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither party is in the Armed Services of the United States or its allies. 7. 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. 9. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order dissolving the marriage between the parties. COUNT II EQUITABLE DISTRIBUTION 10. Plaintiff incorporates the allegations of paragraphs one (1) through nine (9) by reference as if set forth at length herein. 11. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of the parties hereto. 12. The Plaintiff and the Defendant have been unable, as of the date of this complaint, to agree as to an equitable division of said property. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. Date: q,2,8- Og Respectfully submitted, William L. Grubb, Esquire I.D. # 72661 3803 Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 Attorney for Plaintiff VERIFICATION I, Richard C. Spahr, verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: ZF?? Richard C. Spahr, Plaintiff -r, , ? J 7 y? r V ? ? \ RICHARD C. SPAHR, Plaintiff V. PATTY K. SPAHR, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5889 CIVIL TERM Defendant : IN LAW - DIVORCE ACCEPTANCE OF SERVICE I, Patty K. Spahr, accept service of the above captioned COMPLAINT IN DIVORCE. Date ratty K. r c"_, ?,,..? ??? --+ ?. -_ . _ -- c: ??. .,.?. c- RICHARD C. SPAHR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 08-5889 CIVIL TERM PATTY K. SPAHR, Defendant : IN LAW - DIVORCE PrRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above captioned action withdrawn and discontinued. Respectfully submitted, Date b'-t . ?-i , Z4-b 8 William L. Grubb, Esquire Attorney for Plaintiff 3803 Gettysburg Road Camp Hill, PA 17011 (717)763-5580 I.D. 72661 g " an n) - f C-) --4