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HomeMy WebLinkAbout09-3820CAREN SENTER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW FRANCIS J. MOOTZ, III, NO. Gy-3??a Defendant IN DIVORCE NOTICE TO DEFEND 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 FLOWER SAIDIS, LINDSAY 26 West High Street Carlisle, PA SAIDIS, FLOWER & L DSAY /l. a Carol J. Lindsay, -Auire Attorney Id? 4469 26 West Hi reet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff CAREN SENTER, Plaintiff v FRANCIS J. MOOTZ, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW , NO. Of- 38x0 `T.2, IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Caren Senter, an adult individual, residing at 240 Mooreland Avenue, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Francis J. Mootz, III, an adult individual, residing at 240 Mooreland Avenue, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 10, 1985 in Greenwich, Connecticut. 5. There have been no prior actions of divorce or for annulment between the SAIDIS, RFLONVIER LENDS" 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. SAIDIS, FLOWER && LINDSAY Carol J: Lin ay, Esquire ` Attorney Id. 3 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff FLOWER & LENDS" 26 West High Street Carlisle, PA 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. §4904, relating to unsworn falsifications to authorities. Caren Senter Date: FLOWER ? LENDSAY 26 West High Street Carlisle, PA OF THE p? i Fi?7, T 4W ?TY PA. ?33F-f? ?K # as!`?1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Caren Senter v. Francis J. Mootz, III DIVORCE DECREE AND NOW, ~ ~~ ~. 1~ , it is ordered and decreed that Caren Senter plaintiff, and Francis J. MOOtz, III ,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.") The Marriage Settlement Agreement of October 7, 2009, as amended on page 10, is incorporated, but not merged with this Decree in Divorce. By the Court, "~, Attest: J. J~ - Prothonotary NO. 09-3820 a ~ i~ - ~p J~?o yw~~i ~ ~ '~ ~