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HomeMy WebLinkAbout09-0240SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 James R. Demmel, Esquire ID #90918 4431 North Front Street, 3rd Flr. Harrisburg, PA 17110-1778 (7 ] 7) 234-2401 Ismigel~a)sasllp.com jdemmel@.sasl p.com Attorneys for Plaintiff NANCY EICHELBERGER PERKINS, PLAINTIFF v. KIRK A. PERKINS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNnSYLVANIA DOCKET NO. OQ ~ 010 `,-vo 1 TF..fM CIVIL ACTION -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 may 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 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, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 2990 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 of business before the Court. SMIGEL, ANDERSON & SACKS, LLP LeRoy Smigel, Esquire ID #09617 James R. Demmel, Esquire ID #90918 4431 North Front Street, and Flr. Harrisburg, PA 17110-1778 (717)234-2401 lsmieelCa sasllo com jdemmel~a sasllp.com Attorneys for Plaintiff NANCY EICHELBERGER PERKINS, PLAINTIFF v. KIRK A. PERKINS, DEFENDANT : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . DOCKET NO. o g' ~ '~ ~1 a ~`'( ~~ CIVIL ACTION -DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Nancy Eichelberger Perkins, by and through her attorneys, SMIGEL, ANDERSON & SACKS, LLP, and represents as follows: CO- DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Nancy Eichelberger Perkins, who currently resides at 6030 Creekview Road, Mechanicsburg, Cumberland County, Pennsylvania and has resided there since on or about September 2003. 2. Defendant is Kirk A. Perkins, whose residence is unknown to Plaintiff since November 2008. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 5, 2003, at Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff avers that there are no children of the parties under the age of 18. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II EQUITABLE DISTRIBUTION 9. Plaintiff repeats and realleges the averments of paragraphs 1 through 8 which are incorporated by reference herein. 10. Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests this Court to equitably distribute the marital property after an inventory and appraisement has been filed by the parties. SMIGEL, ANDERSON & SACKS, LLP Date: ~ ~ ~ ~ ~ By eRoy S igel, Esquire I.D. #09617 ames . Demmel, Esquire I.D.#: 90918 North Front Street, 3`d Flr. Harrisburg, PA 17110-1778 (717) 234-2401 Attorneys for Plaintiff VERIFICATION I, Nancy Eichelberger Perkins, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ~ /~ - Q l ~ ~ ~ ~ ~ ~~ ~ ':` pa W ~ G 0 '~5 p 0 (St ~ 0 O O ~ 'O _N ~ -- - a A ti ~, --:, ,:... , t z .~ ~ __~ ~, ~ 5 7 ^~ ....._. f--j .r - CJ `m.a~~'' .i _ ~ ~P,. ~{