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Home My WebLink About09-1349 1 JOHN MITCHELL DURHAM, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 9 • J 3 y Civil Term SUSAN K. DURHAM, ACTION IN 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 4a JOHN MITCHELL DURHAM, Plaintiff vs. SUSAN K. DURHAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. D 7 3 V c? Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is John Mitchell Durham, a competent adult individual, who resides at 243 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania, 17112. 2. Defendant is Susan K. Durham, a competent adult individual, who resides at 2475 Enola Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 12, 1976 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together; however, both are adults. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. a 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. §4904 relating to unsworn falsification to authorities. 4 A fed tam John Mitchell Durham, Plaintiff Date: Z?ZB/?? Respectfully submitted, Jane Adams, Esquire I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF n rv C= CZ* ` t i' r x7w , Cnf ?' .c' ? .5 M U Cn JOHN MITCHELL DURHAM, Plaintiff vs. SUSAN K. DURHAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Q? Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this March 12, 2009, I, Jane Adams, Esquire, hereby certify that on or about March 10, 2009, 1 served a copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE on the following individuals, via certified mail, restricted delivery, return receipt requested, at: Susan K. Durham 2475 Enola Road Carlisle, Pa. 17013 DEFENDANT item 4 ft Aeit ? tleaklAd. ¦ Print your rWn* "with se on the reverse y so thet,we can.roWni the r , to you. ¦ Attach this card to the hack of the me0we, or on the front N epaoe pem h. 1. Article Addressed to: r\1 r USC?n k u ham a?-? s End a Rd. Op,rtiske, PA 1-1013 ,ru r,ri L,--C Q.Awd& L ( Lc-al'o of wwwy D. b dMkWY addraaa d 9SM 1t ft= ft" 1? 0 Yea it YES, errte? d*lwy addrsea blow. 0 No 3.?1y1a [ d Mom O 15pai 0 RsOlored Mk%Un f O kaMM114ii11W 13 C.O.D. hlltlfaMll?A'?SFsa) 4. MAIN 2. ANdaWumber 7008 1140 0001 6163 9274 (Mom&#** "n*9 hW Pe Rarm ,1, f 1' 20014 gomeatlo F*t" 14808111 Respectfully Submitted: J Adams, Esquire No. 79465 17 est South St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF for b MOMKIl e 1.1540 r? :K' `? ? ? ?'' ? ?? -...a ? , -_?c?, ?` . r ??, _ t ?,4 CJl ,...! ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN MITCHELL DURHAM, V. SUSAN K. DURHAM, NO 09 - 1349 Civil Term DIVORCE DECREE AND NOW, "M ~ "1 (v L ~- ~ ~ , it is ordered and decreed that JOHN MITCHELL DURHAM, plaintiff, and SUSAN K. DURHAM, ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") None; the marriage settlement agreement which was signed by the parties on April 20, 2010, and was filed on April 27, 2010, is incorporated and not merged into this Decree. By the Court, ~ ~ ~ , r' ~ ;. ~~;; A st: ..° J. i ~~~ P othonotary ~~ ~ G~a~..