HomeMy WebLinkAbout09-2968j ( F:TlLES\Clients\13433 Bailcy\13433.1.Divorce Complaint
Created: 6/1/06 8:50AM
• Revised: 4/30109 8:49AM
Hubert X. Gilroy, Esquire
I.D. 29943
Katie J. Maxwell, Esquire
I.D. 206018
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
TINA M. BAILEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2009- A W
CIVIL ACTION - LAW
ANDREW M. BAILEY,
Defendant 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. Upon your request, the Court may require you and your
spouse to attend up to three sessions. A request for counseling must be made in writing and filed
with the Prothonotary within twenty (20) days of receipt of this Notice.
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.
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 Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
t
TINA M. BAILEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v, NO. 2009- )- I L C?ural•
CIVIL ACTION - LAW
ANDREW M. BAILEY,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Tina M. Bailey who currently resides at 410 A Street, Carlisle,
Cumberland County, Pennsylvania.
2. Defendant is Andrew M. Bailey who currently resides at 410 A Street, Carlisle,
Cumberland County, Pennsylvania.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a
period of more than six (6) months immediately preceding the filing of this Complaint.
4. The parties were married on the 12' day of April, 2007 in Carlisle, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Service Member's Civil Relief Act.
6. There has been no prior action for divorce or annulment instituted by either of the
parties in this or any other jurisdiction.
7. 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.
COUNTI
REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(C) OR (D)
OF THE DIVORCE CODE
8. The prior paragraphs of this Complaint are incorporated herein by reference thereto.
9. The marriage of the parties is irretrievably broken.
10. When at the appropriate time, Plaintiff will file an affidavit stating that two years have
expired from the date of separation.
WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant
to Section 3301 of the Divorce Code.
Date: c? ?(l 0
MARTSON LAW OFFICES
v r'( V)?'
By
Hubert X. Gilr y, Esquire
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
VERIFICATION
The foregoing Divorce Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. The language of the document is that of counsel and not
my own. I have read the Divorce Complaint and to the extent that the document is based upon
information which I have given to my counsel, it is true and correct to the best of my knowledge,
information and belief. To the extent that the content of the document is that of counsel, I have
relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
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TINA M. BAILEY
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Hubert X. Gilroy, Esquire
I.D. 29943
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
TINA M. BAILEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2009- 0411]
CIVIL ACTION - LAW
ANDREW M. BAILEY, :
Defendant IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
prior to the entry of a Final Decree in Divorce,
or after the entry of a Final Decree in Divorce dated , 2009,
hereby elects to resume the prior surname of Sauter, and gives this written notice avowing her
intention pursuant to the provisions of 54 P.S. 704.
Date:
Tina M. Bayley
Tina M. Sauter
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On the /I day of a , 2009, before me, the Prothonotary or the notary public,
personally appeared the above ffiant known to me to be the person whose name is subscribed to the
within document and acknowledged that 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.
OOM O"EALTH OF PENNSYLVANIA
Notary S?
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U Notary Public
FILED4)r-ICE
OF THE PROT'-n' NOTARY
2009 PLAY 12 A 8: 10
CUMB,-"!
TINA M. BAILEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTS', PENNSYLVANIA
v. NO. 2009- d9~ ~
CIVIL ACTION -LAW
ANDREW M. BAILEY,
Defendant IN DIVORCE
ACKNOWLEDGMENT OF SERVICE
I, ANDREW M. BAILEY, Defendant in the above divorce action, hereby acknowledge
receipt and service of the Complaint in Divorce filed in the above matter along with the Notice to
R
Plead o~ n ~ ~ / °l~, 2009.
DATE
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