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Home My WebLink About09-3063Rebecca L. Whisner, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Paul D. Whisner, Defendant : NO. - 3Ea?3 CIVIL TERM 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, Cumberland County Courthouse, 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 (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 or business before the court. You must attend the scheduled conference or hearing. Rebecca L. Whisner, Plaintiff V. Paul D. Whisner, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE :NO. O ? - 304a3 CIVIL TERM DIVORCE COMPLAINT The plaintiff, Rebecca L. Whisner (Moore), by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. §§3301(c) AND 3301(d) 1. Plaintiff is Rebecca L. Whisner, who currently resides at 422 Ricky Road, Mechanicsburg, Cumberland County, PA 17055 since July 2007. 2. Defendant is Paul D. Whisner, whose current physical address is unknown, but is known to receive mailings at P.O. Box No. 904, Mechanicsburg, Cumberland County, PA 17055. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on February 22, 2005 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since January 27, 2008. 6. There have been no prior actions for divorce or for annulment between the parties. 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. 11 WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. 4 Krys J. ac Certified Legal Intern ROBER E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. G Date 2 ( !--? , ?e_z_ Rebecca L. Whisner Plaintiff o I}?c h ^, ,,,rj,RY 2009 MAY 14 Ate 9: 3 4 2'F'P Rebecca L. Whisner, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Paul D. Whisner Defendant NO. 09-3003 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Rebecca L. Whisner, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ,Respectfully submitted, _6?a 0)?Mre_ ?_ ? /7 -) Krys J. aclntyre Certified Legal Intern ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 FILED-0) tcE OF THc",^ 2009 MAY 14 AN 9: 314 S????Yr?lf i` '`r }?i ?i?+,?iy????J REBECCA L. WHISNER, Plaintiff V. PAUL D I, served a 1 Box 904, certified, upon receil green card. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 09 - 3063 CIVIL TERM CERTIFICATE OF SERVICE ystal MacIntyre, Certified Legal Intern, Family Law Clinic, hereby certify that I and correct copy of the Divorce Complaint on Paul D. Whisner, residing at, P.O. chanicsburg, PA 17055 by depositing a copy of the same in the United States mail, tricted delivery, return receipt requested, postage prepaid. Service was complete by Paul D. Whisner, on the the 18th day of May, 2009 as evidenced by the attached 01 N ?• t? Kry aOctyr eal t ` Q $ (?i s Ce 'fled Leg ern E O Megan esmeyer Anne MacDonald-Fox G?a?w o 2a Supervising Attorneys O r v FAMILY LAW CLINIC Ir _ 45 North Pitt Street Ir-• Carlisle, PA 17013 (717) 243-2968 GO :F. `° ° k t Fax: (717) 243-3639 n P 0 ` P ... ebb ? • cn 1 ! ?.'?,,.... L?G?? i t?; > >..? ??s1 a 9 ^ s ? ?j ,a? :7i a?: ,'._ . ._ + . ?.,. i?