HomeMy WebLinkAbout09-3256RONALD C. TURNER,
Plaintiff
vs.
DONNA KAY TURNER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 6?- 3 a s io Civil Term
ACTION IN ANNULMENT
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.
Where divorce is filed, and the grounds 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 Office of the Prothonotary, Cumberland County
Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St.
Carlisle, Pa. 17013
(717) 249-3166
RONALD C. TURNER,
Plaintiff
vs.
DONNA KAY TURNER,.
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 09. 3 2 5(.p Civil Term
ACTION IN ANNULMENT
COMPLAINT IN ANNULMENT
AND NOW COMES, the Plaintiff, Ronald C. Turner, by and through his attorney,
Jane Adams, Esquire, and respectfully represents as follows:
1. Plaintiff is Ronald C. Turner, (hereinafter referred to as "Plaintiff'), a
competent adult individual, who resides at 36 Thompson Creek Drive, Shippensburg,
Cumberland County, Pennsylvania, 17257.
2. Defendant is Donna Kay Turner, (hereinafter referred to as "Defendant"), a
competent adult individual, who resides in West Virginia.
3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6
months immediately previous to the filing of this Complaint.
4. On June 11, 1976 a marriage ceremony was performed between Plaintiff and
Defendant in Macomb County, Michigan.
5. Prior to said supposed marriage of Plaintiff with Defendant, Plaintiff had, in
1960, entered into a valid marriage with Dorothy D. Turner, which marriage was still
existing at the time of the supposed marriage between the two parties to this action.
6. There have been no prior actions of divorce or for annulment between the
parties.
7. Plaintiff and Defendant had 2 children together.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the
United States of America or any of its allies.
10. The Plaintiff avers that the grounds on which this action is based are:
(a) Section 3303 and 3304 of the Divorce Code which provide that a
Decree in Annulment may be granted where either "party at the time of
such marriage had an existing spouse and the former marriage had not
been annulled nor had there been a divorce.... " 23 Pa.C.S. §3304 (a)(1).
WHEREFORE, Plaintiff prays that a Decree in Annulment be entered, declaring
the supposed marriage between Plaintiff and Defendant null and void.
I verify that the statements made in this Complaint are true and correct.
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. §4904 relating to unsworn falsification to authorities.
Ronald C. Turner, Plaintiff
Respectfully submitted,
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?J a ,Adams, Esquire
I. . No. 79465
West South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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