The URL can be used to link to this page

Home My WebLink About09-3533Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 Attorneys for Plaintiff 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 i PETER J. TRIMBLE, IN THE COURT OF COMMON LEAS CUMBERLAND COUNTY, PENNS LVANIA Plaintiff NO. _0q- 3533 ?N1 V. CIVIL ACTION - LAV? BELINDA J. TRIMBLE, IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in he 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 requeste in these pages by the Plaintiff. You may lose money or property or other rights important to y u, 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 Offic of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPER , LAWYER'S FEES OR EXPENSES BEFORE THE 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 N T 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 Count Bar Association y 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Johnson, Duffle, Stewart & Weidner By: Melissa Peel Groovy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PETER J. TRIMBLE, Plaintiff V. BELINDA J. TRIMBLE, Defendant COMPLAINT IN DIVORCE IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, PETER J. TRIMBLE, by and through his attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, BELINDA J. TRIMBLE: 1. The Plaintiff is PETER J. TRIMBLE, an adult individual, residing at 115 Ea$t Woodland Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is BELINDA J. TRIMBLE, an adult individual, residing at 115 Ea$t Woodland Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant were married on July 3, 1997, in Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYVANIA NO. -01. 35" tom' ;,J CIVIL ACTION - LAW of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counseling and the may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court entef a Decree of Divorce under Section 3301(c) or 3301(d) of the Divorce Code. JOHNSO , DUF , STEWART & WEIDNER Melissa Peel Greevy :366583 VERIFICATION I, PETER J. TRIMBLE, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. Date: 5 r PET . TRIMBLE :366583 FbECI- cl1t, 338.60 Pp ATII Gc.- ass3o3 aa5s4V Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I . D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PETER J. TRIMBLE, Plaintiff V. BELINIDA J. TRIMBLE, Defendant AFFIDAVIT CIVIL ACTION - LAW IN DIVORCE PETER J. TRIMBLE, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: S-?lp-0! 4 ? ? < - ??- - PETE T BLE Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS NSYLVANIA CUMBERLAND COUNTY, PE0,1V;ITP-r1, NO. 09 - 3533 v?, Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PETER J. TRIMBLE, Plaintiff V. BELINDA J. TRIMBLE, ' Defendant RETURN OF SERVICE CIVIL ACTION - LAW IN DIVORCE AND NOW, this eday of June, 2009, the undersigned does hereby certify that on June 2, 2009, the Divorce Complaint filed May 28, 2009 in the above captioned action was served upon on Defendant, BELINDA J. TRIMBLE, via certified mail return receipt requested, restricted delivery, addressed to 115 E. Woodland Drive, Mechanicsburg, Pennsylvania 17055, the Return Receipt evidencing service upon Defendant is attached hereto as Exhibit A. JOHNS, DU?FIE, STEWART & WEIDNER Melissa Peel Greevy I . D. No. 77950 Johnson, Duffle, StewartWeidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Plaintiff Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.0 -3553 ¦ Complete Items 1, 2, and 3. Also complete A. Signature item 4 if Restricted Delivery is desired. ? Agent ¦ Print your name and address on the reverse ? Add so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, &B. iv ted Naipe)? \ ate f Deli ery or on the front if space permits. 4 " J? 1. Article Addressed to: 0. Is delivery address different from ml? ? Yes If YES, enter delivery address below: ? No I ?- l 15 11?Di??v?d ?r ti ve i V Y cC?CJ U Ir 5 3. Service type ACertified Mail ? BWess Mail I ? Registered ? Return Receipt fo nQi inarl mail- 171 r, 1% n r Merchandise 4. Restricted Delivery? Pft Fee) Yes 2. Article Number 7007 2680 0001 8112 215 3 (Transfer from service laben PS Form 3811, February 2004 Domestic. Return Receipt 102595-02-M-1 CERTIFICATE OF SERVICE HEREBY CERTIFY that I served a true and correct copy of the foregoing Return of Service upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on th9K_ day of June, 2009, addressed to the following: Belinda J. Trimble 115 E. Woodland Drive Mechanicsburg, PA 17055 JOHNSON, D FIE, STEWART & WEIDNER elissa Peel Greevy :368206 ALEI -.fj- T ICE OF THE PFO - rONOTARY 2009 JUN -9 PM 12: 4.4 PEI NSYLVANIA,