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Home My WebLink About09-3712-r SHERRI D. BLUM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEVIN R. BLUM, :NO. CIVIL TERM Defendant . 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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, Carlisle, Cumberland County, Pennsylvania, 17013. 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 Phone: (717) 249-3166 or (800) 990-9108 s SHERRI D. BLUM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEVIN R. BLUM, : NO. CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Sherri D. Blum, an adult individual currently residing at 126 North Fayette Street, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Kevin R. Blum, an adult individual currently residing at 534 Rich Mar Street, Westminster, Carroll County, Maryland. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 25, 1990, in Blair County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Hannah HermanSnyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: L-1- 61- SHERRI D. BLUM, Plain iff Akz)-' OF THE PROTHONO1'APl 2009 JUN -4 PM 3: Q9 CUMBI FLr*A) (;{JU?N'Y P YVANA. # lf?4, , .l 1158-17YO "+ SHERRI D. BLUM, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW KEVIN R. BLUM, NO. 09-3712 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 1~''day of ~~.w a , 2009, comes Hannah Heiman-Snyder, Esquire, and states that she mailed a certified and true copy of a Complaint in Divorce to the Defendant, Kevin R. Blum, at his address of 534 Rich Mar Street, Westminster, Maryland, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on June 13, 2009. Hannah Herman-Snyder, Es uire Attorney for Plaintiff GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800) 347-5552 Sworn and subscribed #o before me this ~_ day of ~ n2 , 2009 NO RY P LIC !0~ ~ Kart i~ IMI~ry Ilw~ ~~~ ~~. ~~M ~_~_~ ~~M M~MMi ~Nt .~ a~ ~M~i m - ~ .a ,. 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