HomeMy WebLinkAbout09-0002THOMAS H. DACHEUX, : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff, ~ - D~G ~
v. . NO:
NICOLE E. PASCAVAGE-DACHEUX,
:CIVIL ACTION -LAW
IN DIVORCE
Defendant.
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 in divorce or annulment may be entered against you
by the Court. A judgment may also be entered against you for another 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 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
2 LIBERTY AVENUE
Carlisle, PA 17013
(717) 249-3166
P. Richard Wagner, Esquire
PA Supreme Court ID# 23103
Mancke, Wagner, Spreha & McQuillan
2233 North Front Street
Harrisburg, PA 17110
Telephone (717) 2347051
Fax (717) 234-7080
Attorney for Plaintiff
THOMAS H. DACHEUX, : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v. : NO: 6 ~ - 6 6 D ~! -
CIVIL ACTION -LAW
NICOLE E. PASCAVAGE-DACHEUX,
IN DIVORCE
Defendant.
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, Thomas H. Dacheux, by and through his attorneys,
Mancke, Wagner, Spreha & McQuillan, and files the following Complaint in Divorce:
1. The Plaintiff, Thomas H. Dacheux, is an adult individual currently residing at 215
Woodland Avenue Rear, New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant, Nicole E. Pascavage-Dacheux, is an adult individual currently residing
at 4624 Ridge Road, Elizabethtown, Dauphin County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months prior to the filing of this Complaint.
4. Plaintiff and Defendant are husband and wife having been married on or about
October 3, 2006 in Frisco, North Carolina.
5. There have been no prior actions of divorce or annulmem between the parties in this or
any other jurisdiction.
6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States
or any of its Allies.
7. There were no children born unto the marriage.
8. Plaintiff has been advised of the availability of counseling and that he has the right to
request that the Court require both parties to participate in counseling.
9. The Plaintiff avers as grounds on which this action is based are:
A. that the marriage is irretrievably broken pursuant to §3301(c) of the Divorce
Code;
B. that as of November 22, 2010, the parties will have lived separate and apart for a
period of at least two (2) continuous years pursuant to §3301(d) of the Divorce
Code; and
C. that Defendant has offered such indignities to the person of the Plaintiff as to
render the condition of the Plaintiff intolerable and life burdensome pursuant to
§3301(a) of the Divorce Code.
-2-
WHEREFORE, Plaintiffprays this Court to enter a Decree in Divorce.
Respectfully submitted,
Mancke, Wagner, Spreha & McQuillan
i
Richard Gagner, Esquire
Z~`33 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Plaintiff
Date: d ~ D 8
-3-
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904,
relating to unsworn falsification to authorities.
Date: ~ Z
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