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HomeMy WebLinkAbout09-2418~Ei Lavette D. Bryant-Oumarou Plaintiff v. Adamou Oumarou Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA N0.09- a ~/ ~ CIVIL TERM 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 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, 1 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 LO5E 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 5. Bedford Street Carlisle, PA 17013 (717) 249-3166 Layette D. Bryant-Oumarou Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. Adamou Oumarou Defendant N0.09- ~ ~ ~ ~ CIVIL TERM IN DIVORCE COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is L_V ~e~1~. l~ ~,r,~-~ ,,,,,~,..,~„ ,who currently resides at ~~ ~. k`~om~-1- S+P~ C~e~i l~ p ~ ~~la~~ Cumberland County, Pennsylvania. 2. Defendant is _r"I dQ,YYln,l [.~~ ,who currently resides at ~ ~ S?~ S ~ 13~ 5~2~ect I-~~RR'-~~ ~ P ~} ~ 1'l i ~y 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ~pR ~ ~ I ~ . X00''7 at ~..,`PR- 5. The marriage is irretrievably broken, and the parties separated on - n~~~,rr,6e,r~ ~ a~~ 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 5 1 . 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. ~~ I ~s"acx~4 _ Date Plaintiff, Pro Se I, l..W~e.,TtZ.~.~R~,e ~'~-l~.w,aQ~t, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. I - ~ aoo~ Date: l/ MA.JCMJ~.~• X11 L1/L M ^ ^~11 W1/1.0 /r 1 Plaintiff, Pro Se v Assisted by: Darren J. Holst, Esq. Howett, Kissinger & Holst, P.C 130 Walnut St., P.O. Box 810 Harrisburg, PA 17108 (717) 234-2616 t-~~ f7~~1~,.~-~ ... ~^ j~ ry !L .~t is f 2ad~ ~~,~ ~ ~ ~t ~~ 3, CUy, ~~ Lavette D. Bryant-Oumarou Plaintiff v. Adamou Oumarou Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA N0.09- dC~/~ CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, ._.Lavette D. Brvant-Oumarou Plaintiff, to proceed in forma au eris. I, Darren J. Holst, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the p~Y• Darren J. Holst, Esquire, ~P~3 i ~/ Attorney for Plaintiff Howett, Kissinger & Holst, P.C. 130 Walnut St., P.O. Box 810 Harrisburg, PA 17108 (717) 234-2616 i=CL.~L-~~~;W~x.~~' 209 kPR 16 4°`~'i 2~ 32 ._~~~,~~,r,~~i~; ~F~~,~°• Layette D. Bryant-Oumarou IN THE COURT OF COMMON PLEiAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v. N0.09- .Z~l~ CIVIL TERM Adamou Oumarou ~I Defendant IN DIVORCE !, ACCEPTANCE OF SERVICE I, Adamou Oumarou (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. ~.5. §4904, relating to unsworn falsification to authorities. ~= ~a- 04 ~~~vU L,~J~~bl Date Adamou Oumarou, Defendan C}F 'tH~ P~~~#~!~~~~7ARY 2QQ4 JUN t ~ P~ 2~ 23 P~~~~vSY~.V~~~~t~t