HomeMy WebLinkAbout04-2187KEVIN D. YOUNG,
Plaintiff
VS,
DONNA M. YOUNG,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. O -
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 foregoing 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 in 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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
KEVIN D. YOUNG,
Plaintiff
VS.
DONNA M. YOUNG,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO,
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the Court of Common Pleas of Cumberland County. This notice is to advise you that
in accordance with Section 3302 (d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania, You are
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor from this list. All necessary arrangements and the cost of counseling sessions
are to be borne by you and your spouse,
if you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling,
KEVIN D. YOUNG,
Plaintiff
VS.
DONNA M. YOUNG,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, KEVIN D. YOUNG, by his attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is KEVIN D. YOUNG, an adult individual who currently resides at
1532 Thompson Lane in Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is DONNA M, YOUNG, an adult individual who currently resides
at 1532 Thompson Lane in Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on 1 June 1985 in Hershey, Dauphin
County, Pennsylvania.
5, There have been no prior actions of divorce or annulment between the parties,
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
COUNT I -- IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12~ Street
Lemoyne, Pa 17043
(717) 761-5361
I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 18
Pa. C,S. 4904 (unsworn falsification to authorities).
Date:
K E VIN~D. Y~
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2004-02187 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
YOUNG KEVIN D
YOUNG DONNA M
VS
R. Thomas Kline , Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT to wit:
YOUNG DONNA M
unable to locate Her
COMPLAINT - DIVORCE
in his bailiwick.
but was
He therefore returns the
the within named DEFENDANT
, YOUNG DONNA M
NOT SERVED , as to
LOWER ALLEN TWP PD 1993 HUMMEL AVENUE
CAMP HILL, PA 17011
SERVICE STOPPED PER REQUEST FROM ATTORNEY.
Sheriff's Costs:
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
R. Thomas Kline
Sheriff of Cumberland County
SAMUEL ANDES
0~/04/2004
Sworn and subscribed to before me
this 70 ~ day of
~_q. A.D.
Prothonotary
KEVIN D. YOUNG,
Plaintiff
VS,
DONNA M. YOUNG,
Defendant
lin THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 0~-2187 CIVIL TERM
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw the Complaint in Divorce filed by the Plaintiff in this matter.
22 June 2004
Sa~d~t L Andes
Attorney for Plai'ntiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361