HomeMy WebLinkAbout09-3061SMIGEL, ANDERSON & SACKS, LLP
Susan E. Good, Esquire ID #93295
4431 North Front Street, 3`a Flr.
Harrisburg, PA 17110-1778
(717) 234-2401
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Attorney for Plaintiff
JESSICA M. DEVINE,
PLAINTIFF
V.
MICHAEL J. DEVINE, JR.,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - 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 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, 17013.
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 SOUTH BEDFORD STREET
CARLISLE, PA 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 of business before the Court.
I ?I 4
SMIGEL, ANDERSON & SACKS, LLP
Susan E. Good, Esquire ID #93295
4431 North Front Street, 3rd Fir.
Harrisburg, PA 17110-1778
(717) 234-2401
sg,ood( sasllp.conn
Attorney for Plaintiff
JESSICA M. DEVINE,
PLAINTIFF
V.
MICHAEL J. DEVINE, JR.,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. .6 I- 3 6 G l cN .`1 -(e-rn-
CIVIL ACTION - DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR 3301(d)
OF THE DIVORCE CODE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW, comes Plaintiff, Jessica M. Devine, by her attorneys, SMIGEL, ANDERSON &
SACKS, and represents as follows:
COUNTI
DIVORCE UNDER SECTION 3301(c) OR 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Jessica M. Devine, who currently resides at 127 E. Portland Street,
Mechanicsburg, Cumberland County, Pennsylvania and has resided there since on or about April 5,
2009.
2. Defendant is Michael J. Devine, Jr., who currently resides at 165 W. Vine Street,
Shiremanstown, Cumberland County, Pennsylvania and has resided there since on or about November
18, 2006.
-1-
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 26, 2004, at Mechanicsburg,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
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.
8. Plaintiff avers that there are no children of the parties.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
COUNT II
EQUITABLE DISTRIBUTION
9. Plaintiff repeats and realleges the averments of paragraphs 1 through 8 which are
incorporated by reference herein.
10. Plaintiff and Defendant possess various items of both real and personal marital property
which is subject to equitable distribution by this Court.
WHEREFORE, Plaintiff requests this Court to equitably distribute the marital property after
an inventory and appraisement has been filed by the parties.
SMIGEL, ANDERSON & SACKS, LLP
Date: e*r (3?p? By:
usan E. Good, Esquire I.D. #93295
4431 North Front Street, 3rd Flr.
Harrisburg, PA 17110-1778
(717) 234-2401
Attorney for Plaintiff
-2-
. ..t
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsification to authorities.
Date:
OA,
JE I A M. DEVINE
6A)
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2009 HAY 14 AM 19
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SMIGEL, ANDERSON ~[ SACKS, LLP
Susan E. Good, Esquire ID #93295
4431 North Front Street, 3rd Flr.
Harrisburg, PA 17110-1778
(717) 234-2401
sgood&vsasl Ip.com
Attorney for Plaintiff
JESSICA M. DEVINE, 1N THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 09-3061
MICHAEL J. DEVINE, JR.,
DEFENDANT CIVIL ACTION -DIVORCE
ACCEPTANCE OF SERVICE
I accepted service of the Divorce Complaint under Section 3301(c) or 3301(d) of the Divorce
Code on this ~g~ day of , 2009.
Mi ael J. Devine, Jr., De endant
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