HomeMy WebLinkAbout08-7238
EMILY O. DAVIS,
v.
:1N THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
:1N DIVORCE
ANTHONY F. DAVIS,
Defendant
:NO. gt i; 3I C I (/? 1 ?-?r ?'1'?
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 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:
Office of the Prothonotary
Cumberland County Court House
I Courthouse Square
Carlisle, Pennsylvania 17013
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.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
EMILY O. DAVIS, :1N THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. :CIVIL ACTION - LAW
:IN DIVORCE
ANTHONY F. DAVIS
Defendant :NO. 6 12 3 7 ewu l
COMPLAINT
AND NOW comes the Plaintiff, Emily O. Davis, who, by and through her
attorneys, Elizabeth S. Beckley, Esquire, Charles O. Beckley, II, and Beckley & Madden,
of Counsel, files this Complaint, in which she avers that:
1. Plaintiff, Emily O. Daivs, is an adult individual residing at 2929 Beverly
Road, Camp Hill, Cumberland County, Pennsylvania 17011.
2. Defendant, Anthony F. Davis, is an adult individual residing at 2929
Beverly Road, Camp Hill, Cumberland County, Pennsylvania 17011.
3. Both parties were bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of the original
Complaint.
4. Plaintiff and Defendant were married on October 11, 1986.
5. There have been no prior actions in divorce or for annulment between the
parties in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling and that
Plaintiff or Defendant has the right to request the Court to require the parties to
participate in such counseling.
COUNTI
REQUEST FOR A NO-FAULT DIVORCE
UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE
8. The averments contained in Paragraphs 1 through 7 of this Complaint are
incorporated herein by reference as though set forth in full.
9. Plaintiff's marriage to Defendant is irretrievably broken.
10. Plaintiff has been advised that counseling is available and that she may
have the right to request that the Court require the parties to participate in counseling.
WHEREFORE, pursuant to 23 Pa.C.S.A. §§3301(c) or (d), Plaintiff, Emily O.
Davis, respectfully requests the Court to enter a Decree of Divorce.
DATED: a-lv-ty Respectfully submitted,
of Counsel
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
2
VERIFICATION
I, Emily O. Davis, hereby verify that the statements made in the foregoing
document 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 18 Pa. C. S.
Section 4904, relating to unsworn falsification to authorities.
DATED: ?-0'q
?'? 0, - -tW-4.0
Emily O. Davis
C) N
71
CD <
EMILY O. DAVIS,
V.
JN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
ANTHONY F. DAVIS,
Defendant
:CIVIL ACTION - LAW
:IN DIVORCE
:NO. 08 - 7238
ACCEPTANCE OF SERVICE
I, Anthony F. Davis, hereby accept service of the Divorce complaint filed in the
above-captioned action.
DATED: /?- /oZ ®G zigE...
ony F. Da
e-55
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ITI
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EMILY O. DAVIS, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANTHONY F. DAVIS,
DEFENDANT NO. 08-7238 CIVIL TERM
DIVORCE DECREE
AND NOW, ??h mar-, 07(? , it is ordered and decreed that
EMILY O. DAVIS , plaintiff, and
ANTHONY F. DAVIS , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
NONE. The Property Settlement Agreement between the parties shall be incorporated
into the final decree for purposes of enforcement but shall not merge with the final
Decree in Divorce.
By the Court,
Attest: J.
Prothonotary
--,- 4 Aam,44