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Home My WebLink About09-1802u 04 ROBERT F. MCCREARY, Plaintiff V. TERRA C. MCCREARY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. - IN DIVORCE 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 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: Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6196 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. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 r 1% Anthony T. McBeth, Esquire 407 North Front Street Harrisburg, PA 17101 (717) 238-3686 Attorney for Plaintiff ROBERT CR RY, I HE COURT O COMMON PLEAS F Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. U 9 - / PJ z.l T ?c?.?,. TERRA C. MCCREARY, IN DIVORCE Defendant 1. Plaintiff is Robert F. McCreary, who currently resides at 445 Linden Street, Mechanicsburg, Cumberland County, Pennsylvania, since May, 2007. 2. Defendant is Terra C. McCreary, who currently resides at 700 Rupp Avenue, #3, Mechanicsburg, Cumberland County, Pennsylvania, since February, 2009. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 15, 2001 at New Cumberland, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 1 V, 7. Neither Plaintiff nor Defendant is an active member of any of the branches of the United States Armed Services; therefore, neither party enjoys the protections of the Soldiers and Sailors Civil Relief Act of 1940, as amended. 8. 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. 9. Plaintiff requests the court to enter a decree of divorce. Ruw.,' t 11- Date --' Attorney for Pla' fti Fi l%j 407 North Front Harrisburg PA 17101 2 (717) 238-3686 Supreme Court I.D. 53729 . VERIFICATION I, Robert F. McCreary, Plaintiff in the foregoing action, verify that the facts set forth in the attached document are true and correct to the best of my knowledge, information and belief. I so state subject to the penalties of 18 Pa. C. S. §4904 (relating to unsworn falsification to authorities). MARCH 19, 2009 tiff ate. Robert F. McCrea r , 4 .? o d K k ? V N 0 c. j !T! f Ci:r '• s r` r ry ca N W N W 4.) 1 n9 -C 0 Anthony T. McBeth, Esquire 407 North Front Street Harrisburg, PA 17101 (717) 238-3686 Attorney for Plaintiff ROBERT F. MC REA Y, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 09-1802 Civil Term TERRA C. MCCREARY, IN DIVORCE Defendant AFFIDAVIT OF SERVICE PURSUANT TO PA. R. CIV. P. 405 I, Anthony T. McBeth, Esq., attorney for the Plaintiff in the captioned action, hereby swear that I have served the Complaint upon the Defendant in the captioned action by mailing a certified copy of same to her addressed as follows: Terra C. McCreary, 700 Rupp Avenue, #3, Mechanicsburg, PA 17055. Said mailing was by first class mail, postage prepaid, certified, return receipt requested. Said mailing was effected on March 24, 2009. The return receipt, purportedly bearing the signature of James Shertzer, who both the undersigned and the Plaintiff know to be an adult member of the Defendant's household, and who the undersigned and Plaintiff both know to be Defendant's brother, and showing a delivery date of March 24, 2009, is attached hereto, marked Exhibit "A" and incorporated herein by reference. A A i A ate me &Nan1 ?7 Ae 13 t3q?e.eMd ? Rehun Reosipt fa Ms?m>?e 1 0 ineasd fold ? C.O.D. 4. Radricted DeBvery? Pft Poe) ? lbe 2. Attide Number ('Ae?a1Mr Atlrft 0eltabe N? ? ' ?' ??? p1 PS Farm 3811, February 2004 Domestic Retum Receipt 102WrM44.1540 A. Sipndm X Agot S. Received by (Prfrmed +Wrne) C. Dabs of DOMY D. b delvery 1 "' dK Mart "KIM 17pp UU 1. ArWe Addmosed to: K YES, enter d*vwy add h? O -7 ,are 1k)l `u Ite ¦ Conosto m 4 N Item t, 2, mW 3. Also c fis PA*bW Delivery Is red. ¦ Print your name and address on the roverm so that we can return the card to you. ¦ Attach this card to the beck of the maNpkm, or on the front if space permits. EXHIBIT "A" COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Sworn and subscribed before me 2009. My commissions expires: COMMONYMALTH OF PENNSYLVANIA Notarial Seal Mdwa S. Myers, Notary Pu 3k Olaf Of Fug, County W Coaedssion E)Oms June 11, 2011 M WWW, Pennsylvanla Association of Notaries this day of Atco OF ,?r o i?OM zo APR -1 -2: 52 AAQM4 AM ROBERT F. MCCREARY, Plaintiff V. TERRA C. MCCREARY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-1802 Civil Term IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated since May 1, 2007 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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. JUNE 25, 2009 X00, V Date Robert F. McCreary, P ff ROBERT F. MCCREARY, Plaintiff V. TERRA C. MCCREARY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-1802 Civil Term IN DIVORCE CERTIFICATE OF SERVICE I, Anthony T. McBeth, Esquire, Attorney for Plaintiff, hereby certify that I have served the attached document by placing same in the United States mail, first class, postage pre- paid addressed as follows: r J5 2 to Terra C. McCreary 700 Rupp Avenue, #3 Mechanicsburg, PA 17055 hthony T. McBfl? Esq. Attorney for PIajfitiff\ 407 North Front t., irst Floor Harrisburg, PA 17101 (717) 238-3686 Supreme Court I.D. # 53729 OF THE Pr,,:)Ti-,C= rO7ARY 2009 .SUN 25 PM 1: C 2 PE+N ULV,4NA