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HomeMy WebLinkAbout09-2166KAREN S. GALBRAITH, Plaintiff v. RONALD J. GALBRAITH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. Oq - o~l(~ (. Civ i l ~C~ 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 i~' 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 Prothonotary's OfFce, Cumberland County Courthouse, Cumberland, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT ISi,GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEIivI. 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. 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 FED OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Cazlisle, PA 17013 (800) 990-9108 r KAREN S. GALBRAITH, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW NO. ~>_ ~ / G G /~ RONALD J. GALBRAITH, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, KAREN S. GALBRAITH by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, RONALD J. GALBRAITH, upon the gro,~unds hereinafter set forth: 1. Plaintiff is KAREN S. GALBRAITH, an adult individual, residing at 127 Long Road, Apartment 1, Newville, Cumberland County, Pennsylvania. 2. Defendant is RONALD J. GALBRAITH, an adult individual, residing at 15 Rays Drive, Newville, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 28, 2008, in )oiling Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of United States of America. 7. The Defendant is not a member of the Armed Services of the United States. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff, KAREN S. GALBRAITH respectfully requests this Honorable Court to enter a Decree in Divorce pursuant to the Divorce Code. DATED: ~.. r ' ~ 7 Respectfully submitted,' ~. Robert B. Lieberman, )squire 500 N. Third Street, 12~' Floor P.O. 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint in Divotce are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to uns~vorn falsification to authorities. DATED: ~) ~) "" O ~ ~ ~------~°• /J KAREN S. GALBRAI'fH Plaintiff FlLEL~-t~c-lC GE THE P?~~-~''~iJTA~i'Y ~QQ~ APR -6 P~~ 3~ I l~ CU~a' a t.; iii?Y ~:=~t~~~, w a. ~' `" `ti`p ~t~"~~„~ $ 338.5a Quo A~ CX.~' 81010 3 ~T'~" 0~0'133(y KAREN S. GALBRAITH, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW NO. 09-2166 CIVIL TERM RONALD J. GALBRAITH, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 6, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. 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. Dated: ' RONALD J Defendant ~lLED-~::t~rlC~ 0~ 'THE PFz~ ~ ~~",~t?TARY 2009 SAP -4 PM 3~ D i VWS'~74f ,t~.; 1YVU ~J~~l/jVf ~ ~SYl.VAPd~A KAREN S. GALBRAITH, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 09-2166 CIVIL TERM RONALD J. GALBRAITH, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. Dated: / fi1~f~-~~rlCE x~~9 SEP ~~ ~~ 3~ G 1 ViJtY1`..J~..~{~./'tivr''1..+ ~~~*l~+Jp~IVI 1 ~i V7 ~!~ 1 ~„~I'11 Yf!'1