HomeMy WebLinkAbout09-1803FOREST W. PRICE,
Plaintiff,
V.
AUBREE L. PRICE,
Defendant
To: Aubree L. Price:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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DOCKET NO: COQ '"' ~ ~ l~ ~ U ~~ l~~
CIVIL ACTION -LAW
: 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, ls~ Floor,
1 Courthouse Square, Carlisle, Pennsylvania 17103.
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, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY COURTHOUSE
4TH FLOOR
CARLISLE, PA. 17013
#717-240-6200
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FOREST W. PRICE,
Plaintiff,
V.
AUBREE L. PRICE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DOCKET NO: o g--- 1 ~d3 C,w~! T-~-~"~
CIVIL ACTION -LAW
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR (D) OF THE
DIVORCE CODE
AND NOW, this day of March, 2009, comes the Plaintiff, Forest W. Price,
by and through his undersigned attorney, Joseph L. Hitchings, Esquire and avers in
support of his Divorce Complaint as follows:
1. Plaintiff, Forest W. Price, is an adult individual currently residing at 520
Springhouse Road, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. Defendant, Aubree L. Price, is an adult individual currently residing at 124 West
Portland Street, Unit 25, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
3. Both parties have been bona fide residents of the Commonwealth of Pennsylvania
for at least six (6) months immediately prior to filing of this Complaint.
4. Plaintiff and Defendant were married on September 27, 2008, in Mechanicsburg,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The ground on which the divorce action is based is that the marriage is
irretrievably broken.
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7. Plaintiff has been advised that counseling is available and that the 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.
9. No children have been born of this marriage.
WHEREFORE, pursuant to 23 Pa. C.S.A. §3301 (c) or (d), Plaintiff, Forest W.
Price, respectfully requests this Court grant a Decree of Divorce, divorcing the parties
from the bonds of matrimony.
Respectfully Submitted,
Law Office of Joseph L. Hitchings
Joseph L~itchings, quip
Attorney ID No. CS551
5000 Ritter Road, Suite ,
Mechanicsburg, PA 17055
(717) 458-8123
(717) 790-6019 (fax)
Attorney for Plaintiff
VERIFICATION
I, Forest W. Price, verify that the statements made in this Divorce Complaint are true and
correct to the best of my knowledge. I understand that false statements herein are made subject
to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.
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Date Forest W. Price
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