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HomeMy WebLinkAbout09-1564? , a BRIAN E. YEOMANS, : IN TIE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO. 6 /,SG y CIVIL TERM LORI A. YEOMANS, Defendant : IN DIVORCE NOTICE 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 ofyour 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 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 Phone: (717) 249-3166 A# BRIAN E. YEOMANS, Plaintiff Vs. LORI A. YEOMANS, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 69 _ /'6 ? CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Brian E. Yeomans who currently resides at 1203 Newburg Road, Shippensburg, Cumberland County, Pennsylvania, 17013 since November 2006. 2. Defendant is Lori A. Yeomans who currently resides at 4686 Third Avenue, Niagara Falls, Ontario, 12E465, since October 2008. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 17, 2001, at Pleasant Hall, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for 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. Plaintiff requests the Court to enter a Decree of Divorce. Ilk, Y 'i I r 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 unworn falsification to authorities. Date: Cd 9 Brian E. Yeomans, laintiff ANDREWS & JOHNSON By: Ronald E. J on, Esq. Attorneys laintiff 78 W. Po et Street Carlisle, PA 17013 (717) 243-0123 n ^? I-n t 7D . °x t f r. rj A ,r. BRIAN E. YEOMANS, v. LORI A. YEOMANS, I, LORI A. husband, BRIAN E. YEO Cumberland County, DATE: Mv\ c6c\kc- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUSTODYNISITATION : NO. 09- 15 (q CIVIL TERM ACCEPTANCE OF SERVICE hereby accept service of the Complaint in Divorce filed by my to the above number and term in the Court of Common Pleas of and acknowledge receipt of a true copy thereof. ID,?7 Lori A. Y 01mans, Defendant is ?°l?l ?arkl??'ll pr, So1?nSh?..?n '? A 1 Sg09 FiLEC 'Y?1CE OF THE P?O-TI PM 3TARY 2009 APR -9 PM 3= Q 4 t,luMb r.1?14?fi1 I e f^ E ft- of Irsy"WVNIA,