Loading...
HomeMy WebLinkAbout09-3142v ?% \\Carlisle\e\KLaw\Firm Docs\Clients Files\4419-1 Rochelle RichardWivorce.complaint.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROCHELLE M. RICHARD, Plaintiff V. ROBERT K. RICHARD, Defendant CIVIL ACTION - LAW Cam.. NO.2009- 3t?1.2, Ct ui L l f rn 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 maybe 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYERAT 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, 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. F. "b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROCHELLE M. RICHARD, Plaintiff V. CIVIL ACTION - LAW NO.2009- ,3I Y Z -? ROBERT K. RICHARD, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this day of May, 2009, comes Plaintiff, Rochelle M. Richard, by and through her attorneys, Sean M. Shultz, Esquire, and Knight & Associates, P.C., and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Rochelle M. Richard, who resides at 82 Tannery Road, Dillsburg, York County, Pennsylvania 17019. 2. The Defendant is Robert K. Richard, who resides at 14 South Broad Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant are sui juris, and Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on June 19, 1989, in Warrensburg, Missouri. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Section 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. 6. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same. w , -1% WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, KNIGHT & ASSOCIATES, P.C. I ? S<? Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff -.. A. VERIFICATION The foregoing Complaint in Divorce 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 Complaint in Divorce 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 unworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties., R helle M. Richard ,A 1 Irv OF T my 2009 fa A;Y S P 3: 02 NT y t w..h I ;Y:ErAf'l '338. f 0 ?t?? r8^r9 eK-:e-