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HomeMy WebLinkAbout09-2392JEREMY HOLLINGSWORTH, Plaintiff V. SHEENA HOLLINGSWORTH, Defendant : IN THE COURT OF COMMON FLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. D? - 013ga CIV? I l?rm CIVIL ACTION - LAW : 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 on the first floor of the Cumberland County Courthouse, Carlisle, Cumberland County, PA. 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 TELEPOONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 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 the Court Administrator at (717) 7:0-6624. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. Melanie L. Erb, Esquire 2132 Market Street Camp Hill, PA 17011 717-975-9446 Merbkdcdlaw.net JEREMY HOLLINGSWORTH, Plaintiff V. SHEENA HOLLINGSWORTH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 4- : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Jeremy Hollingsworth, by and through his attorney, Melanie L. Erb, Esquire and the Law Offices of Darrell C. Dethlefs, who brings this Complaint in Divorce and avers as follows: 1. Plaintiff is Jeremy Hollingsworth, an adult individual currently residing at 330 S. Washington Street, Apt. 2, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Sheena Hollingsworth, an adult individual currently residing at 5312 Oxford Circle, Apt. 6, Mechanicsburg, Cumberland County, Pennsylvania., 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff avers that Defendant has also been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately pri or to the filing of this Complaint. 5. The parties were married on July 26, 2001 in Mechanicsburg, Cumberland County, Pennsylvania. 6. Plaintiff and Defendant separated in June 9, 2006. 7. There have been no prior actions of divorce or annulment between the parties. 8. The marriage is irretrievably broken 9. Plaintiff avers that neither party is an active member of the United States Military or its allies. 10. 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. Be so advised, Plaintiff waives that right. 11. Plaintiff avers that Defendant has been advised of the availability of counseling and that Defendant may have the right to request that the Court require the parties to participate in counseling. 12. Plaintiff avers the grounds for divorce: a. The marriage is irretrievably broken; b. The parties consent to the divorce; or in the alternative, c. The parties have lived separate and apart for a period or two (2) years. WHEREFORE, Plaintiff, Jeremy Hollingsworth, respectfully requests this Honorable Court grant a Decree in Divorce pursuant to Section 3301 (c) or (d) of the Divorce Code. Respectfully Submitted, 4x e., o t / - - Melani L. rb, re Attorney I.D. No. 84445 The Law Offices of Darrell C.'Dethlefs 2132 Market Street Camp Hill, PA 17011 717-975-9446 Attorney for Plaintiff VERIFICATION I, JEREMY HOLLINGSWORTH, verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. X109 - REMY LLINGSWORTH DATE OF THE A,rK t t1a6?AY 20L99 APR Tly 33g. 50 PAD ATT( Ri"?' aa? 8os JEREMY HOLLINGSWORTH, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-2392 Civil Term SHEENA HOLLINGSWORTH, : CIVIL ACTION - LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: I, Sheena Hollingsworth, do hereby accept service of the Complaint in Divorce in this matter. g/ ,a-o 9 Date Sheena Hollingsworth 2 6 0 9 P 30 v'i`a 2: Li L?