HomeMy WebLinkAbout09-0129Sandra L. Meilton, Esquire
Daley Zucker Meilton Miner & Gingrich, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717)657-4795
smeilton ,dzmmglaw.com
JOSEPH M. HUMMER, II
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. b~- o~a9 C~~<< T~rw
MELANIE S. HUNIMER :CIVIL ACTION -LAW
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 aze 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 mamage counselors is available in the Office of the
Prothonotary at the Cumberland County Court House, Cazlisle, 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
32 S. Bedford Street
Carlisle, PA 17013
Telephone No. (717) 249-3166 or 1-800-990-9108
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(Sandra L. Menton, Esquire
Attorney I.D. 32551
DALEY ZUCKER MEILTON
MINER & GINGRICH, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Attorney for Plaintiff
Sandra L. Meilton, Esquire
Daley Zucker Meilton Miner & Gingrich, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
smeilton(a,dzmm g l aw.com
JOSEPH M. HUMMER, II
Plaintiff
v.
MELANIE S. HUIVIMER
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~ ~~ ~ z 9 ~.! 7fu.--~
CIVIL ACTION -LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301~c) OF THE DIVORCE CODE
1. Plaintiff is Joseph M. Hummer, II, an adult individual who is sui juris and resides at
5830 Spring Tree Court, Enola, Cumberland County, Pennsylvania.
2. Defendant is Melanie S. Hummer, an adult individual who is sui juris and resides at
5830 Spring Tree Court, Enola, Cumberland County, Pennsylvania.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 22, 1991, in Harrisburg,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Plaintiff has been advised of the availability of counseling and the right to request
that the Court require the parties to participate in counseling.
7. The Defendant is not a member of the Armed Services of the United States or any of
its Allies.
8. The Plaintiff avers that the ground on which that the marriage is irretrievably
broken.
WHEREFORE, if both parties file Affidavits consenting to a divorce after ninety
(90) days have elapsed from the date of the filing and service of this Complaint, Plaintiff
respectfully requests the Court to enter a Decree of Divorce pursuant to §3301(c) of the Divorce
Code.
Respectfully submitted,
DALEY ZUCKER MEILTON
MINER & GINGRICH, LLC
andra L. Meilton, Es uire
Attorney I.D. No. 32551
1029 Scenery Drive
Harrisburg, PA 17109
717-657-4795
Attorneys for Plaintiff
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Dated: 1- ~-G`l ~~,,.~ ~
Joseph M. Hummer, II, Plaintiff
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