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HomeMy WebLinkAbout09-2189 DALE M. EURICH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - CIVIL TERM JILL L. EURICH, CIVIL ACTION-LAW 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 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, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL 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. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 DALE M. EURICH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA I V. NO. 2009 - Z(9-q CIVIL TERM JILL L. EURICH, CIVIL ACTION-LAW Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Dale M. Eurich, an adult individual who currently resides at 327 Stoner Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Jill L. Eurich, an adult individual who currently resides at 327 i It Stoner Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents in 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 16, 1994 in Dillsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he 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. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. W COUNT II -EQUITABLE DISTRIBUTION 9. Plaintiff hereby incorporates by reference paragraphs 1 through 8 above. 10. The parties have acquired real estate, personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. Respectfully submitted, Date; ?"6`o-'-? O'BRIEN, BARIC & SCHERER i h e A. Scherer, Esquire I. DI 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff mas.dir/domestic/eu rich/divorcecomplaint.pid VERIFICATION I verify that the statements made in this Complaint 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. Date: J "?-? - ® 9 Dale M. Eurich RLED--OFRCE OF THE P ? d (}T'MY 2009 APR -7 PM 3: 12 t?4?? a i, i? n {P,! PE? SFr d ? ? ,r"4 N.741 f 3T?- . ,d?rdti? (cam ?-fi G o C) 3 6 y . 3"6 Ck l* ? 3 4 4 ? A DALE M. EURICH, Plaintiff V. JILL L. EURICH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 2189 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this day of 2009; I, Jill L. Eurich accept service of the Divorce Complaint in the above-captioned case. LIZ Jill L. Eurich , FILUD OF THE 2 009 A ,P 20 PN ?, 0 4 CUM'