HomeMy WebLinkAbout09-4143JENNIFER MACHIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. OJT'- yif3 Civil Term
ALEXIS MACHIN, : CIVIL ACTION - LAW
Defendant : 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.
Where 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 at the Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St.
Carlisle, Pa. 17013
(717) 249-3166
JENNIFER MACHIN, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 0q. zrl q3 Civil Term
ALEXIS MACHIN, : CIVIL ACTION - LAW
Defendant : DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Jennifer Machin, a competent adult individual, who has resided at
21 Cornman Road, Carlisle, Cumberland County, Pennsylvania, 17013 since November
22, 2008.
2. Defendant is Alexis Machin, a competent adult individual, who resides at 203
Gettysburg, Street, Dillsburg, York County, Pennsylvania, 17019.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
for at least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on July 1, 2005 in Cumberland
County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. Plaintiff has been advised that counseling is available and that plaintiff may
have the right to request that the court require the parties to participate in counseling.
7. Plaintiff and Defendant have one child together, namely, Mariana Machin. On
or about April 13, 2009, a custody complaint was been filed under No. 2009 - 2291 in
Cumberland County.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the
United States of any of its allies.
10. The Plaintiff avers that the grounds on which this action is based are:
(a) that the marriage is irretrievably broken pursuant to 23 Pa.C.S.
3301(c);
(b) that Plaintiff has suffered such indignities as to render her condition
intolerable and life burdensome pursuant to 23 Pa.C.S. 3301(a)(6).
WHEREFORE, Plaintiff requests the court to enter a Decree in divorce.
Respectfully submitted,
oate?71d y
ne Adams, Esquire
.D. No. 79465
17 West South Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
VERIFICATION
I verify that the statements made in this Complaint 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 falsification to authorities.
Date: o 9
s
C A
Je ifer M in, PI intiff
OF
a,ARY
2004 AN 17 PM 3: 5 3
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