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HomeMy WebLinkAbout09-2808MICHELLE YVONNE FRADY, Plaintiff V. EARL ERNEST FRADY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO.09- IN DIVORCE CIVIL TERM NOTICE 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, High and Hanover Streets, Carlisle. 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 S. Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 MICHELLE YVONNE FRADY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW EARL ERNEST FRADY, JR., : NO. 09- 2- CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Michelle Yvonne Frady, who currently resides at 7 Cedar Road, Carlisle, Middlesex Township, Cumberland County, Pennsylvania, 17015. 2. Defendant is Earl Ernest Frady, Jr., who currently resides at 7 Cedar Road, Carlisle, Middlesex Township, Cumberland County, Pennsylvania, 17015. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on February 15, 1991, in Camp Hill, Pennsylvania. 5. Plaintiff and Defendant separated on or about May 1, 2009. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. 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. 9. Neither party is now serving in the United Armed Forces, nor have ever served in the United States Armed Forces. 10. Plaintiff requests the Court to enter a Decree in Divorce. By: W11 Paul Bradford Orr, Esquire Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID # 71786 VERIFICATION I verify that the statements made in the foregoing Divorce 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: 2-L6q FAQ-OFFICE OF TWE PROTHONOTARY 2009 MAY -5 AM 9: 4 3 CUM f A--*D COUNTY P N{ Y VANS s-33g". b- any Rte- y? Y!o ? ? a MICHELLI? YVONNE FRADY, Plaintiff V. EARL ERI LEST FRADY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09- o?96R_ CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COM COUNTY WEALTH OF PENNSYLVANIA ) :)F CUMBERLAND ) NOW, this 15th day of May, 2009, 1 Paul Bradford Orr, Esquire, attorney for Michelle F ady, Plaintiff, in the above-captioned action, hereby swear that I have served a true cop of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested. The original return receipt card signed by the Defendant on May 13, 2009, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Dated : 5' lq?cq' By: Paul Bradford Orr, Esquire I . SP I$ Complete ftm 1, 2, and 3. Also complete A. Signadae. Rem 4 if Restricted Delivery Is desired. X , ¦ Print your name and address on the reverse so that we can retum the card to you. B. Received by (PAW Nmm) ¦ Attach this card to the back of the mallplece, G' or on the front If space permits. L I1. D. Is delivery address different from Rem Amide Addressed to: tf YES, enter delivery address below. rakt -7 Cj-da? CaS l 1 -1015 Agent ? Yes ?mo 3. Service Type 10 Certmed Mall 0 Express Mail 0 PAQisMW Or Rewm Receipt for Merdta WIN © IrraftL* ? C.O.D. 4. Raub+cllffiAall.wryl (E:aa Fee) ?!( Yes I2. Article Number murmArOwnar+r"bekw 7008 3230 2002 8008 2694 INS Form 3811, FSWuWy 2004 Domestic FWNWIVANOW loeeas M4A-1540 Exhibit "A" PILE IF OF THIFF 2009 "4 j 20 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHELLE YVONNE FRADY V. EARL ERNEST FRADY, JR. NO 09-2808 DIVORCE DECREE AND NOW, ~d.~,.~~t ~~ , z•o7 , it is ordered and decreed that MICHELLE YVONNE FRADY plaintiff, and EARL ERNEST FRADY, JR. ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, Atte J . ~ r onotary .t ti •! ;" ~ .,.tea,.., . R:~