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HomeMy WebLinkAbout09-1185CONNIE L. TRAXLER, : IN THE COURT OF COMMON PLEAS OF Plaitrtiff :CUMBERLAND COUNTY, PENNSYLVANIA ~. :Civil Action- Law ROY G. TRA30.ER, Defendant IN DIVORCE ~~ 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 annuhnerrt maybe entered against You by the court. A juc~ment may also be entered against You for a~+ other claim or relief requested in these papers by the Plaintiff. You may also lose money or property or other rigl~#s 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU SO NOT FII,E A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 Phone: (71'n 249-3166 (800) 990-9108 AFRICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of C'~mberland Cou~y is required by law to comply with the A~ricxuns with Disabilities Act of 1990. For information about acvessible facilities and reasonable aoocmmtiodationsevailable to disabled individuals having business before the court, Please oomact our office. All ~ must be made at least 72 hours prior to a~ hearing or business before the court. Yon must atte~ the scheduled coufenence or hearing. t CONNIE L. TRAXLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. C~6J' 11 ~S~ ~~ !' ~ ROY G.1'RAXL.ER, Defendant IN DIVORCE CO~":Pia.AINT UNDER S__F.C,"rIONS 330~11e1 or 33QI.(d) Q~' THE DIVORCE CODE AND NOW, comes the Plaintiff, Connie L. Trailer, by and through her counsel, Michael J. Where, Esquire and avers as follows: 1. Plaintiff is Connie L. Trailer, an adult individual, who currently resides at 606 Sandbank Road, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. Defendant is Roy G. Trailer, an adult individual, who currently resides at 606 Sandbank Road, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six momhs immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 28, 1994, in Mt. Holly Springs, Cumberland County, Pennsylvatia. 5. There have been no prior actions of divorce or annulment between the parties hereto in this or any other jurisdiction. 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. Plairniff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, at Michael J. e, Esquire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plairniff ~_ , ,, . CONNTE L. TRAXLER, : IN THE COURT OF COMMON PLEAS OF Plairniff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. ROY G. TRAXLER, Defendant IN DIVORCE VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statemerns herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: 0~ - dt G ~ a~~ ~ ~.4~ ~.. ~ ~ `` , T'~~„~c Connie L. Trailer, Plairniff ~ (.. wV .~. = -n ~ ~ --~ I +~ \ ~ Y ~ 4 ` ^ / -• ~/ ~ ` \ `vV V