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HomeMy WebLinkAbout09-0755Divorce Complaint ORIGINAL Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road, Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100 • Fax: 717-975-0697 • Email: dianeradcliff @comcast.net Attorney for Samuel S. Beiler IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMUEL S. BEILER, Plaintiff NO. 09 - '1S Civil berm v. : CIVIL ACTION - LAW. MARY A. BEILER, : 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 of 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, (COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDER YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS ATA REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 ,?.? ?, ? : ?^ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMUEL S. BEILER, . Plaintiff NO. v Y- 7 SS C,;a V. CIVIL ACTION- LAW MARY A. BEILER, DIVORCE Defendant COMPLAINT Plaintiff, Samuel S. Beiler by attorney, Diane G. Radcliff, Esquires, and files this Complaint in Divorce of which the following is a statement: 1. The Plaintiff is Samuel S. Beiler, an adult individual who currently resides 62 S. Old Stonehouse Road, Carlisle, Cumberland County, PA 17015; 2. The Defendant is Mary A. Beiler, an adult individual whose last known address is 62 S. Old Stonehouse Road, Carlisle, Cumberland County, Pk 17015. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 28, 2005' at Harrisburg, Dauphin County, PA. 5. Plaintiff avers that there are no children under the age of eighteen (18) years born of the marriage. 6. There have been no prior actions of divorce or annulment', between the parties. 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. Defendant is not a member of the Armed Services of the United States or any of its Allies. -1- 9. Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a decree of divorce; WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully submitted, FF, ESQUIRE Camp Hill, PA 17011 Phone: (717) 737-0100 Supreme Court ID'# 32112 Attorney for Plain tiff -2- VERIFICATION SAMUEL S. BEILER verifies that the statements made in this Complaint are true and correct. SAMUEL S. BEILER understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ww ago. SAMUEL S. BEILER Date: February 11, 2009 -3- -n `o rti? 3 J --- ? M Y co L.? -C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMUEL S. BEILER, Plaintiff NO. 09-755 V. CIVIL ACTION - LAW MARY A. BEILER, IN DIVORCE Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY OF THE SAID COURT: Please reinstate the complaint filed in the above referenced case on February 12, 2009. Respectfully Submitted, D IFF, ESQUIRE l ( e R ration No 32112) 3448 Trindle Road, Camp Hill, PA 17011 Email: dianeradcliffCcomcast,net Phone: (717) 737-0100 • Fax: (717) 975-0697 Counsel for Plaintiff Dated: April 28, 2009 RLED- 0,; OF THE ' TARy 2009 APR 29 Fli 1: 2 U` 2 410.00 A© A-ny &If 4631 er* aaq4t 7