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Home My WebLink About09-1883Jeffrey R. Boswell, Esquire Supreme Court I. D. No. 25444 BOSWELL, TINTNER & PICCOLA 315 North Front Street, P. 0. Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Attorney for Plaintiff Paul R. Troutman PAUL R. TROUTMAN, : IN THE COURT OF COMMON PLEAS PLAINTIFF, : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. U 9 - P P3 ?P- CHRISTINA M TROUTMAN, DEFENDANT. : 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling you must make your request for counseling within TWENTY DAYS (20) of the date on which you received this notice. Failure to do so will constitute a waiver of your right to request counseling. 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 (717) 1-800-990-9108 Jeffrey R. Boswell, Esquire Supreme Court I. D. No. 25444 BOSWELL, TINTNER & PICCOLA 315 North Front Street, P. O. Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Attorney for Plaintiff Paul R. Troutman PAUL R. TROUTMAN, PLAINTIFF, V. CHRISTINA M TROUTMAN, DEFENDANT. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 0g- )?P3Q Ieu. IN DIVORCE COMPLAINT IN DIVORCE UNDE" 33011c1 OF THE DIVORCE CODE AND NOW COMES the Plaintiff, Paul R. Troutman, by his attorneys, Jeffrey R. Boswell, Esquire, and Boswell, Tintner & Piccola, and states the allegations of this Complaint, as follows: 1. The Plaintiff, Paul R. Troutman, is an adult individual who currently resides at 404 Center Street, Enola, Cumberland County, Pennsylvania 17025, since June, 2004. 2. The Defendant, Christina M. Troutman, is an adult individual who currently resides at 700 Nailor Drive, Apartment 108, Camp Hill, Cumberland County, Pennsylvania 17011, since September, 2008. I The Plaintiff and the Defendant have been residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 28, 2000, in Enola, Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant separated on August 1, 2007. 6. Plaintiff avers that there are no borne children of this marriage. 7. The Plaintiff and Defendant are both citizens of the United States. 8. Neither the Plaintiff nor the Defendant are members of the Armed Services of the United States. 9. 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. 10. The parties may enter into a written agreement with regard to property division, in which case such agreement may be merged or incorporated into the Final Decree of Divorce. 11. There have been no prior actions of divorce or annulment in any Court in this Commonwealth or elsewhere. 12. Plaintiff requests this Court to enter a decree of divorce. COUNTI DIVORCE BY MUTUAL CONSENT 13. Paragraphs 1 through 12 are hereby incorporated by reference. 14. The cause of action of the Divorce Code under which Plaintiff is proceeding is, as follows: Section 3301(c) Mutual Consent - The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant will also file an affidavit consenting to a divorce. WHEREFORE, the Plaintiff respectfully requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. BOSWELL, TINTNER & PICCOLA By: ?)'? J R. Boswell, Esquire Attorneys for Plaintiff, Paul R. Troutman DATE: March 23, 2009 VERIFICATION I, Paul R. Troutman, Plaintiff, hereby verify that the facts contained in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. 2/ PAUL .TROUTMA Dated: March 23, 2009 CERTIFICATE OF SERVICE I, Jeffrey R. Boswell, Esquire, do hereby certify that I have served a true and correct copy of the Complaint in Divorce, as follows: Christina M. Troutman 700 Nailor Drive Apartment 108 Camp Hill, PA 17011 Method of Service: X First class mail X Certified mail/Restricted Delivery Other BOSWELL, TINTNER & PICCOLA By: Jeff . Boswell, Esquire Dated: March 23, 2009 C) N d G 7 n Ul O U ?I- Jeffrey R. Boswell, Esquire Supreme Court I. D. No. 25444 BOSWELL, TINTNER & PICCOLA 315 North Front Street, P. O. Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Attorney for Plaintiff Paul R. Troutman PAUL R. TROUTMAN, PLAINTIFF, V. CHRISTINA M TROUTMAN, DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1883 IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. Jeffrey R. Boswell, Esquire, being duly sworn according to law, deposes and says that I am a competent adult, and that I mailed a copy of the Complaint in Divorce on the Defendant, Christina M. Troutman, on March 25, 2009. The Defendant received the Complaint on or about March 26, 2009, as evidenced by the attached return receipt card attached hereto. Je y . Boswell, Esquire Sworn to and subscribed before me this a7?L day of March, 2009 Notary Public My Commission Expires: ?OMfJiOi+tf$e t a' LVANA y fYtmber, s?erm ?r?.?,:. .. ?otart2s ELED-422:FNCE OF THE P:'C" I ant%fOTARY 2009 APR -7 PM 3.54 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. A. X n -L ? Agent 1. Article Addressed to: 171- :3?; hq 1W • Troup Q,? I L'u mp ?/? ?fI /70i/ B. Received by (Printed Name) D. Is delivery address different from item 1? ? WE If YES, enter delivery address below: ? No 3. fS?ervice Type ygCertifled Mail ? Express Mail 13 Registered Return Receipt for Merchandise ? Insured Mail C.O.D. 4. Restricted Delivery? (Extra Fee) 1111 Yes 2. Article Number 7004 2890 0002 8000 8998 1 (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 c-° e?.? wr, _.? " 4 .._S ?. ...... ? S . ..'.:i ? .. ' S.? ??;,«