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HomeMy WebLinkAbout09-3545v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Lawrence Brian Hollister Plaintiff Pro Se, vs. NO. UQ- 3 511 5 C,;;,{ , Jennifer Ellen Hollister Defendant Pro Se. 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 at Cumberland County Courthouse, S. Hanover St., Carlisle, PA 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. 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 LAWYERS REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 The Court of Common Pleas of Cumberland County is required by lave 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 the Court Administrator at (717) 240-6195. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. Notice to Defend and Claim Rights Page 1 of 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Lawrence Brian Hollister 403 Mercury Drive Mechanicsburg, PA 17050 Plaintiff Pro Se, vs. Jennifer Ellen Hollister 5460 Joshua Road Mechanicsburg, PA 17050 Defendant Pro Se. NO. 6 9_ 3 Sv5' &;?j Tz- COMPLAINT IN DIVORCE UNDER §3301(c) OF THE DOMESTIC RELATIONS CODE Count I-Divorce Plaintiff, Lawrence Brian Hollister, pro se, respectfully represents: 1. Plaintiff, Lawrence Brian Hollister, currently resides at 403 Mercury Drive, Mechanicsburg, PA 17050. 2. Defendant, Jennifer Ellen Hollister, currently resides at 5460 Joshua Road, Mechanicsburg, PA 17050. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have has/have been resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4.. The parties were married on 08/29/1998, in Harrisburg, PA. 5.. The parties were separated on 01/23/2009. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 7. The following children were born to the parties: Name Age Sex Laine McKenna Hollister Complaint in Divorce Date of Birth Residence 2 female 09/19/2006 Both Father and Mother Page 1 of 2 8. There have been no prior actions of divorce or for annulment between the parties. 9. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, spousal support, child support, custody, visitation, fees and costs. 10. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 11. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. If a divorce based on consent cannot be granted, Plaintiff further alleges in the alternative that the marriage is irretrievably broken and the parties will have been separated for two years or more at the time of final disposition of this case. WHEREFORE, Plaintiff requests this Honorable Court to enter a d ee in divorce pursuant to Section 3301(c) of the Divorce Code. 111.4e? L wrence an Mist Plaintiff Pro Se VERIFICATION Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the nalties of 18 Pa. C. S. Section 4904, relating to unswom falsification to authorities. / ?/./%? Lawrence Bri WRoll&Lrr, Printiff Pro Se Date: S'2q - CA Complaint in Divorce Page 2 of 2 F 71, I~ C r,f C-,s`rY At, /9, f Ic 33 ?'Sb ,? ? s? *77 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Lawrence Brian Hollister Plaintiff Pro Se, vs. NO. C9 Jennifer Ellen Hollister Defendant Pro Se. ACCEPTANCE OF SERVICE I, Jennifer Ellen Hollister, defendant in this divorce action, hereby certify that I personally received a copy of the Complaint in Divorce with a Notice to Defendant and Claim Rights on or about_ AU Al 'fer E ollister, Defendant -Mt Date: Exhibit A: Acceptance of Service Page 1 of I R) EL ? -a > TIMP 2009 JUN - ? Pil 2= 3',