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Home My WebLink About09-4756McNEES WALLACE & NURICK LLC By: Debra D. Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 260-1667 facsimile dcantor _mwn.com MELISSA A. RIVERS, Plaintiff V. CHRISTOPHER M. RIVERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Oq - W756 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 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, One 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 McNEES WALLACE & NURICK LLC _ By I ;ZL D or Attorney ID No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 (717) 260-1667 (fax) dcantor(@-mwn.com Attorneys for Plaintiff Melissa A. Rivers Dated: July 14, 2009 McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantorC&-mwn.com Attorneys for Plaintiff MELISSA A. RIVERS, Plaintiff V. CHRISTOPHER M. RIVERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. QV - y75 5--6 c- Pv.,'l : IN DIVORCE COMPLAINT AND NOW comes Plaintiff, Melissa A. Rivers, by and through her counsel, McNees Wallace & Nurick LLC, and files the following Complaint in Divorce. COUNTI Divorce Under 3301(c) or 3301(d) of the Divorce Code 1. Plaintiff is Melissa A. Rivers, who currently resides at 1319 Old Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Christopher M. Rivers, who currently resides at 1319 Old Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 27, 2001 in Jamaica. 5. Plaintiff and Defendant are the parents of one minor child, Bradyn P. Rivers, born December 24, 2005. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. 9. After 90 days have elapsed from the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 10. In the alternative, Plaintiff will file a 3301(d) Affidavit and provide the appropriate notices two years from the date of separation. WHEREFORE, Plaintiff, Melissa A. Rivers, respectfully requests the Court to enter a decree of divorce under Section 3301(c) or (d) of the Divorce Code. COUNT 11 Indisanities Under 3301(a)(6) of the Divorce Code 11. Plaintiff incorporates by reference paragraphs I through 10 of this Complaint. 12. Defendant has offered such indignities to Plaintiff (who is the innocent and injured spouse) as to render Plaintiffs condition intolerable and life burdensome and to create an unsafe environment for the parties minor child. 13. This action is not collusive as defined by Section 3309 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301(a)(6) of the Divorce Code. COUNT III EQUITABLE DISTRIBUTION 14. Plaintiff incorporates by reference paragraphs I through 13 of this Complaint. 15. Plaintiff and Defendant possess various items of personal marital property, as well as marital debts, which are subject to equitable distribution by this Court. WHEREFORE, Plaintiff, Melissa A. Rivers, requests your Honorable Court to equitably distribute all property, both real and personal, owned by the parties, as well as all marital debts. McNEES WALLACE & NURICK LLC By D r -tor Attorney ID No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 (phone) (717) 260-1667 (fax) dcanto r _mwn.corn Attorneys for Plaintiff, Melissa A. Riversa Dated: July 14, 2009 VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Dated: 711,) /CI'F f?titJ xh- Mclissa A. Rivers FVI.EG _?si ? L, OF THE 2099 JL?L 16 PM 1: 5 5 CUVI pz 338.So PA AIN i- A(o . 00 Egyit Dis+ ? -So Po Am CV-' !8f8L(8 P-T*,2,28080 McNEES WALLACE & NURICK LLC By: Debra Denison Cantor Attorney ID No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor(a)-mwn.com Attorneys for Plaintiff MELISSA A. RIVERS, Plaintiff V. CHRISTOPHER M. RIVERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-4756 : IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint in the above matter. ;?*??4 hristopher M. Rivers Dated: 7- ??- e?f tt Le: ?. Uu 4 " f 1',lr