HomeMy WebLinkAbout09-0133TONI R. BIXLER,
Plaintiff,
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
:2009 - 133
JEFFREY L. BIXLER,
Defendant.
IN DIVORCE
NOTICE
CIVIL TERM
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 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 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 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 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
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.
TONI R. BIXLER,
Plaintiff,
v.
JEFFREY L. BIXLER,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2009 - ~ 3 3 CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTIONS 330~~ AND D~ OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Toni R. Bixler, and files this Complaint in Divorce against
the Defendant, Jeffrey L. Bixler, representing as follows:
1. The Plaintiff is Toni R. Bixler, an adult individual with a mailing address of 99
West Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266.
2. The Defendant is Jeffrey L. Bixler, an adult individual currently residing at 44
Sandy Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013.
4. The Plaintiff and Defendant have been residents of the Commonwealth of
Pennsylvania at least six months prior to the filing of this action in divorce.
5. The Plaintiff and the Defendant were married on August 26, 2004 in Cumberland
County, Pennsylvania and separated on or about August 28, 2006.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as
the grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
8. The Plaintiff avers that she has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling.
WHEREFORE, the Plaintiff respectfully requests a judgment dissolving the marriage
between the two parties.
Respectfully submitted,
IRWIN & McKNIGHT
Dated: January ~, 2009 By:
Dougla .Miller, Esquire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
2
w.
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unsworn falsification to authorities.
~(/YLC
TONI R. BIXLER
Date: /-9-09
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