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Home My WebLink About09-2323Tabitha Vantassell, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Shawn Vantassell, Defendant : N0.09- ~. ~ 2 ~ CIVIL TERM 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, Cumberland County Courthouse, 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, 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 Baz Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Tabitha Vantassell, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE Shawn Vantassell, Defendant : N0.09- ~ 3.2 3 CIVIL TERM DIVORCE COMPLAINT The plaintiff, Tabitha Vantassell, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. ~~3301(a)(6), 3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Tabitha Vantassell, who currently resides at 226 Key West Blvd., Cazlsle, Cumberland County, PA 17015, since November, 2000. 2. Defendant is Shawn Vantassell, whose last known address is 110 Regency Woods North Cazlisle, Cumberland County, PA 17013 since April 1, 2009. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on December 7, 2002 in Carlisle, Cumberland County, Pennsylvania. 5. Defendant offered such indignities as to the innocent and injured Plaintiff as to render Plaintiff's condition intolerable and her life burdensome. 6. Plaintiff and Defendant have lived sepazate and apart since February 16, 2009 7. There have been no prior actions for divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Kry al J. acIn ~e Certified Legal Intern i, E. RAINS y~;e~`~~`-. ROB T THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorney . FAMILY LAW CLINIC 45 North Pitt Street Cazlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. ~_ __,_., ,_,~.. ~---'" :^.- Date ~ /~/ O `~. iff -''° __ a itha Vantassell 2QQ9 APR i ~ ~~i I~~ ~ ~. T ~~~ Tabitha Vantassell, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN DIVORCE Shawn Vantassell Defendant NO. 09-a 313 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Tabitha Vantassell, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date t Respectfully submitted, Krys J. M In ` Certified Legal Intern ROBE THOMAS .PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C}~ THc F~ ~~- ~~~ ~TI~F?Y Z~og ~~~ ~ ~ aM ~a: ~ z ~'rr~vs'?'`'i'~~,1~t F~,'t