HomeMy WebLinkAbout09-37391
LAWRENCE GLENN,
Plaintiff
V.
SARA ARIAS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
: NO. 2009 - 3V CIVIL TERM
DIVORCE
NOTICE TO DEFEND 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, 1 Courthouse Square, Carlisle, Pennsylvania.
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 A 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.
Pennsylvania Lawyer Referral Line
Lawyer Referral Services
Telephone: 1-800-692-7375 (PA ONLY)
or 717-238-6715
LAWRENCE GLENN,
Plaintiff
V.
SARA ARIAS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:NO. 2009 -?7 39 CIVIL TERM
: DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
NOW comes Plaintiff and for cause of action against Defendant who says:
Plaintiff is Lawrence Glenn, who resides in Shippensburg, Cumberland County, with a
street and mailing address of 305 East King Street, # 3, Shippensburg, Pennsylvania 17257.
2.
Defendant is Sara Arias, who resides in Shippensburg, Cumberland County, with a street
and mailing address of 305 East King Street, # 3, Shippensburg, Pennsylvania 17257.
3.
Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this complaint.
4.
Plaintiff and Defendant married on March 2, 2007 in Brevard County, Florida.
5.
There have been no prior actions for divorce or annulment of marriage between the
parties in this or any other jurisdiction.
6.
The marriage is irretrievably broken.
7.
Plaintiff has been advised of the availability of counseling and that Plaintiff may have the
right to request the Court to require the parties to participate in counseling.
8.
Defendant is not a member of the Armed Services of the United States or any of its allies.
9.
The causes of action and sections of the Divorce Code under which the Plaintiff is
proceeding are:
A. Section 3301(c): The marriage is irretrievably broken.
B. Section 3301(d): The marriage is irretrievably broken and the parties have been
living separately and apart. If the parties do not agree to proceed under Section 3301(c) of the
Divorce Code, then Plaintiff will submit an Affidavit alleging that the parties have lived
separately and apart for at least two (2) years and that the marriage is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a Decree of
Divorce, divorcing the parties from the bonds of matrimony.
Respectfully Submitted,
NEUHARTH LAW OFFICES
Paul M. Ferguson
Supreme Ct. No.: 203293
Attorney for Plaintiff
P.O. Box 359
232 Lincoln Way East
Chambersburg, PA 17201
(717) 264-2939
VERIFICATION
I verify that the statements made in this document are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities.
9'&ZO 9
Date
1 ? le 2d.c
Lawrence Glenn
R O-OFFICE
OF THE PHMT
2009 JUN -8 AM 10: 02
PENNSYLVANfA,
Pi $ V - v )#j
--
LAWRENCE GLENN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
SARA ARIAS, : NO. 2009 - 3739 CIVIL TERM
Defendant
DIVORCE
AFFIDAVIT OF SERVICE
I, Paul M. Ferguson, of Neuharth Law Offices, hereby state that on June 10, 2009, I
mailed by First Class U.S. Mail, and on July 7, 2009, I mailed by Certified. Mail, No. 7008 1830
0002 4201 0912, Return Receipt Requested, Addressee Only, a copy of the Complaint in Divorce
to Defendant Sara Arias at 305 East King Street, # 3, Shippensburg, Pennsylvania 17257, the last
known mailing address of Defendant, which documents were received on July 9, 2009, as
evidenced by the attached Domestic Return Receipt. (See Attached Exhibit A).
Paul M. Ferguson
Supreme Ct. ID #: 203293
Attorney for Plaintiff
Neuharth Law Offices
P.O. Box 359
232 Lincoln Way East
Chambersburg, PA 17201
(717) 264-2939
¦ 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 card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
A.
X
by (Printed Name)
iA
D. Is delivery address different from item 1? 0 Yes
If YES, enter delivery address below: ? No
3. Service Type
19 a S 7 0 Certified Mail
0 Registered
0 Insured Mail
0 Egress Mail
0 Return Receipt for Merchandise
? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
2. Article Number 7008 1830 0002 4201 0 912
(Aarmfor from serv/ce law
Ps Form 3811, February 2004 Domestic Return Receipt 1025e5-02-W1540
Exhibit A
Fi`ED4
20C, 91 u, . 1 k kC'i 10: 14
Cl
ft
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Lawrence Glenn
V.
Sara Arias
NO. 2009 - 3739
DIVORCE DECREE
AND NOW, /Vers..,G+,r y Zook , it is ordered and decreed that
Lawrence Glenn ,plaintiff, and
Sara Arias ,defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None.
By the Court,
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Prothonota ~
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