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Home My WebLink About09-17381 V LAUREN MOORE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO: o9- 039' tr,l FREDRICk C-MOORE, II Defendant IN DIVORCE NOTICE TO DEFEND FLOMrM & LIlVDISAY 26 West High Street Carlisle, PA 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 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY --AAA J Mary ou tas, Wuirg- Aft orney 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff V LAUREN MOORE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 09- !7 3ffcN• 1 FREDRICK C. MOORE, II NO: Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Lauren Moore, an adult individual currently residing at 38 Spring Garden Estates, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Fredrick C. Moore, II, an adult individual currently residing at 38 Spring Garden Estates, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 23, 2005 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. Neither the Plaintiff nor the Defendant are members of the United States FLONVE,RR & LINDSAY 26 West High Street Carlisle, PA Armed Forces or its Allies. 7. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 (c) or (d) of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Ma atas, Es ire Attorne d. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: 3?J/o9 Counsel for Plaintiff FLONVERR & LINDSAY 26 West High Street Carlisle, PA is LAUREN MOORE, Plaintiff V. FREDRICK C. MOORE, II Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: IN DIVORCE VERIFICATION ?I I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsifications to authorities. I LAUREN MOORE Date: 3 J q / oQ VM & a izimAY 26 West High Street Carlisle, PA p a w ?..r CTN LAUREN MOORE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO: 2009-1738 FREDRICK C. MOORE, II Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Marylou Matas, Esquire, being duly sworn according to law, hereby deposes and says that on March 24, 2009 she served a true and correct copy of a Complaint in Divorce upon Fredrick C. Moore, II, my mailing those documents to the his address at 38 Spring Garden Estates, Carlisle, PA 17013 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Fredrick C. Moore, II. Respectfully submitted, Dated: 3/Zs /0 9 'FLOWER & LR4DSAY Analaflaw 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY Yv Marylou #atas, Esq ID No. 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Y r19Ml?L.Irai4\m Delivery isdoolred • P*t 'y(w name end addroes on the rV#Vm so WhOIwe csn rokrn {lRcold Wyou. IN Adech this card to the back of the rnallpiece, or on the front N epece permits. 1. Miele Addmned to: ?k . Ynoor? rr, 3 prc r)q C l F r?o L3 X, 0 Agent rrd-CM . #6& 03- $ Y D. Is delivery eddens d m t lbrrr 1? ? yse If YES, entx delivery address below X"o & earvicsTA. Xc.rue.a AM O fti•ee hell. 0 ReilleI n O Retr+n Reodpt for M«eAerrNN 0 hosed MeN 0 C.O.D. 4. Ree"Mad DeMryt (Exba Fie) b(1!s 2. Mile Akerrber (lianeWftm&*wbo 7001 2510 0000 3040 0546 PS Form 3811, February 2004 Donreellc Retum ReoeiWt 1025ee-0¢.M.1540