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HomeMy WebLinkAbout09-2300EMILY H. DAMRON, Plaintiff V. CHRISTOPHER T. DAMRON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 4y- 030 : CIVIL ACTION - LAW : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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 Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 EMILY H. DAMRON, Plaintiff V. CHRISTOPHER T. DAMRON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary EMILY H. DAMRON, Plaintiff V. CHRISTOPHER T. DAMRON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Emily H. Damron, who currently resides at 433 Springhouse Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Christopher T. Damron, who currently resides at 2100 Cedar Run Drive, Apt. 101, Camp Hill, Cumberland County, Pennsylvania 17011. 3. 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. Plaintiff and Defendant were married on September 21, 2002, in Perry County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. The parties to this action have been separated since March 21, 2009. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the Court to enter a Decree in Divorce. 11. This action is not collusive. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 12. Plaintiff and Defendant are the owners of various real and personal property, motor vehicles and bank accounts acquired during their marriage which are subject to equitable distribution by this Court. WHEREFORE, the Plaintiff requests the Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; b. equitably distributing all property owned by the parties hereto; and c. for such further relief as the Court may determine equitable and just. Respectfully submitted, Dated: April 13, 2009 By: JAMES, SMITH, DIETTERICK & CONNELLY, LLP Courtney Kish Po ell Attorney I.D. # 1509 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff Emily H. Damron e VERIFICATION I, Emily H. Damron, verify that the statements made in this Pleading are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date: q1 6 I 4. Emily H. D n i F FILED-CF-TIE r?E C?Ixi OF TINE PROTHONOTARY 2099 APR 13 PM 3+ 02 ?,j?'_t;_ ?,^.•? }? h-ter W ?1 V U EMILY H. DAMRON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-2300 CHRISTOPHER T. DAMRON, : CIVIL ACTION - LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Christopher T. Damron, hereby accept service of the Complaint for Divorce filed on April 13, 2009 in the above-captioned action. Dated: `? / 4 v 7 Christopher T. Damron, Defendant FILFD--O.r=i'{;E OF THEE 2009 APR 17 P 1: 12 rr"jl} t Pyy ...V '.s? . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C7rn i Lu ? 1??m rar? Plaintiff 0? ' Vs File No. 2-300 Chos?oW,- T Dkmrm IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/ defendant in the above matter, [select one by marking "x"] X prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of EM, U {{. n 111a6Y and gives this written notice av wMg his /her intention pursu o e visio of/5 S. 704. Date: l? Tz-?5 lu"i S Z Signatur f name being resumed COMMONWEALTH OF PENNSYLVANIA ) I (? nd J3S 11'1gE?'' COUNTY OF whirl ) On the 'lay of J k,ne , 200 9, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. vi&? Notary Public OMMO WEALTH PENNSYLVANIA Notarial Seal Lon A. 13. Zerbe, Notary Public City Of Harrisburg, Dauphin County 's Member, ennsylvaMa Assoolalim ni FILED-,.), i=- l yE OF THE f'' 0Pjf', +i Y 2009 JUN 26 Phi 1: 6 W?:/ Y ?:./ tlu4 PENNSYLVANIA 00 Pip A-rH ?`? as D