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HomeMy WebLinkAbout09-0006F:\User Folder\Firm Docs\Cliems Files\4346-I Ty Jones\divorce.complaint.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TY W. JONES, Plaintiff CIVIL ACTION -LAW v. NO. ~ - OOO(o BRANDI L. JONES, Defendant 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 maybe 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TffiS 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 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TY W. JONES, Plaintiff CIVIL ACTION -LAW BRANDI L. JONES, ; Defendant 1N DIVORCE COMPLAINT IN DIVORCE AND NOW, this ~ day of December, 2008 comes Plaintiff, Ty W. Jones, by and through his attorneys, Knight & Associates, P.C., and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Ty W. Jones, who is on active service with United States Armed Forces, whose military residence is 530 Lowewood Place, Chula Vista, California 91910, and whose permanent residence is Cumberland County, Pennsylvania. 2. The Defendant is Brandi L. Jones, who resides at 249 Pine Grove Road, Gazdners, Cumberland County, Pennsylvania 17324. 3. The Plaintiffand Defendant are sui juris, and Defendant has been a bona fide resident of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on June 13, 1998, in Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. The foregoing facts aze averred and brought under Section 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. 6. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, KNIGHT & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint aze true and correct to the best of my knowledge, information and belief. This Verification is made by Plaintiff s counsel based upon information provided by Plaintiff to Plaintiffs counsel regazding the factual averments contained herein, which has been verified by Plaintiffby the attached copy of Plaintiff s Verification. I understand that false statements herein aze made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. Sean M. Shultz, Esquire ~ ~ ~ ~ ~ ~"? ^" ~' -~• ^ d ~~ ~ 1 + 1 ~~ F ; - -. N ; ~ _ ~ , -~. ,.. t,. ~ .. "1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA i ~~ ~bn~ s Plaintiff Vs File No. ~ ~DOa(o s IN DIVORCE ~ ra nr.,l ~ L. Jones Defendant ~'~'? ~ {~r: ate. ;~ -_* ~ ~r~ .~: -~ ...~. • ~ £ ~~ t.. °na :._ ~ NOTICE TO RESUME PRIOR SURNAME a~_ ~ .. Notice is hereby given that the Plaintiff /defendant in the above matter, °~ [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or ~ after the entry of a Final Decree in Divorce dated~S(~n 14 Zok~, hereby elects to resume the prior surname of~r0.r~d; L4v,n I~ly Q,rS ,and gives this written notice avowing his /her intention pursuant to the provisions of 54 P.S. 704. Date: a~ ~QilGb_ (~ ,( Si nature Pi4 +~ ~y 3 6/397 Yl~l~ ~. ~ 71`f~ ~L1 A S ~S'~ijg.~na~ture of na being resumed COMMONWEALTH OF PENNSYLVANIA ) "~ "" " ~ ~~~ COUNTY OF Cw~w6~rlw~~, On the .7-~~' day of M a rG ~- , 20~ d , before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he /she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Notary Public -mac rn~ c: ~~. frT'+ $~i,oo pd ~d-t cas ~ ~~~3~yy woa~"w~w~ ~.~ ~~~o