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Home My WebLink About09-3770MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff TERRY E. SNYDER, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. REBECCA M. SNYDER, Defendant NO.09-agwCIVIL TERM CIVIL ACTION -LAW 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 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 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 the Cumberland County Courthouse, Carlisle, Pennsylvania 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 INFORMATON 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, PA 17013 Telephone: (717) 249-3166 MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff TERRY E. SNYDER, JR. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09. 3714 of 7&1 REBECCA M. SNYDER, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Terry E. Snyder, Junior, who has resided at 1406 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania, for the last five (5) years. 2. Defendant is Rebecca M. Snyder, who has resided at 4 Dulles Drive West, Apartment G1, Camp Hill, Cumberland County, Pennsylvania, for the last two (2) months. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 6, 2000 in Virginia Beach, Princess Anne County, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces. 7. Plaintiff and Defendant are both citizens of the United States. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. Plaintiff avers that there are no children of the parties under the age of eighteen. COUNT I - DIVORCE 10. Plaintiff avers that the grounds on which the action is based are as follows: that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court enter a decree in divorce. Respectfully Submitted: MARIA P. COGNETTI ASSOCIATES Date: June 1, 2009 By: A(M A ETTI, ESQUIRE MARIA . CO(G Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff VERIFICATION I, Terry E. Snyder, Jr., hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. oaC? Date: I Terry E. Snyder, Jr. r** BLED-OF r OF THE PP4THOWTAR1 2009 JUN -8 PM 12= 51 ?.: •?.; i'Li COUNTY CUMBE P NSYLVAN A 4338.50 00 Airy OX-0 q sag P-Tt aa(- a'70 A# --?' 0,.t, - / 70se) V 7? -)ri a-.L, 1,7011 d MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff TERRY E. SNYDER, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 09-3770 REBECCA M. SNYDER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, MARIA P. COGNETTI, ESQUIRE, do hereby certify that a true and correct copy of the Complaint in Divorce was served upon Defendant, Rebecca M. Snyder, by certified mail, return receipt requested, on June 15, 2009. The original signed return receipt, number 7008 0150 0002 5365 2594 is attached hereto and made a part hereof. Respectfully submitted, MARIA P. CQGNETTI & ASSOCIATES Dated: June 22, 2009 By: MARIA Pr COiGrJETTI, ESQUIRE Attorney I.D. N %A7914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff v ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the cans to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: KG-&,X,4 M. 5AJqbF-k q c u1(ls . 4 Camp A. Signature X B. Recelyed by (1 ? Agent \D a of Delivery D. Is delivery address d rertt frolrvt 1? J !3 Yes If YES, enter delive dress l rr b No N?a 3. ice Type qLcwmw Mail ? Express Mail Registered etum Receipt for Merchandise ? Insured Mail C.O.D. 2. Article Number 708 0150` .-..5.._..,, 9 4-.__ ._ _. '36 2594 (Transfer from service k bO PS Form 3811, February 2004 Domestic Return Receipt 102595-024+1540 S4 a ?P c.J a Y1