HomeMy WebLinkAbout09-5382
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Kevin M. Stago,
Plaintiff
VS.
Tira L. Stago,
Defendant
CIVIL ACTION--LAW
IN DIVORCE
NO. j!59 -s3g-I-, L91Uc C Z
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NOTICE TO DEPEND 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.
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, Cumberland
County Courthouse, 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 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
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Kevin M. Stago,
Plaintiff
VS.
Tira L. Stago, .
Defendant
CIVIL ACTION--LAW
IN DIVORCE
NO. 09 ^ .S3 g,,Z_ (2t COMPLAINT UNDER SECTION 3301(c) OR 3301(d
OF THE DOMESTIC RELATIONS CODE
AND NOW, comes Plaintiff, Kevin M. Stago, by and
through his attorney, Fiona K. Line, and files the
following Complaint in Divorce, and in support thereof
avers as follows:
1. Plaintiff is Kevin M Stago, an adult individual, who
currently resides at 104 Mountain Lane, Enola, Cumberland
County, Pennsylvania 17025 since 1991.
2. Defendant is Tira L. Stago, an adult individual, who
currently resides at 147 Tory Circle, Enola, Cumberland
County, Pennsylvania 17025 since June 12, 2009.
3. Plaintiff has been a bona fide resident in the
Commonwealth of Pennsylvania for at least six (6) months
immediately preceding the filing of this Complaint.
4. The Plaintiff and Defendant were married on September
21, 1991 in Marysville, Pennsylvania.
5. The Plaintiff and Defendant were separated on or about
June 12, 2009.
6. There have been no prior actions of divorce or for annulment
between the parties.
7. The Plaintiff and Defendant are not members of the armed
forces of the United States or any of its allies.
8. The Plaintiff avers that the marriage is irretrievably
broken.
9. Plaintiff has been advised of the availability of counseling
and that the Plaintiff may have the right to request that the
Court require the parties to participate in counseling. The
Plaintiff does not desire counseling.
10. Plaintiff requests the Court to enter a decree of divorce.
Dated: 7 / p?_
?° Cx-s?
VIONA IMBERL -LINE
Attorney ID 65283
Attorney for Plaintiff
1817 Basin Hill Blvd.
Carlisle, PA 17013
(717) 991-1382
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Kevin M. Stago,
Plaintiff
VS.
Tira L. Stago,
Defendant
CIVIL ACTION--LAW
IN DIVORCE
NO.
VERIFICATION
I verify that the statements made in the foregoing Complaint
in Divorce are true and correct to the best of my knowledge,
information and belief. This Verification is made only as to the
factual averments contained herein, and not to legal conclusions
and averments authorized by counsel in her capacity as attorney
for the party or parties hereto. 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.
KEVIN M. ST G
Q),
FILr..., a w?
OF THE F"
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KEVIN M. STAGO
v.
TIRA L. STAGO
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 09-5382 CIVIL TERM
DIVORCE DECREE
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AND NOW, ~ ~y , it is ordered and decreed that
KEVIN M. STAGO
TIRA L. STAGO
bonds of matrimony.
plaintiff, and
defendant, are divorced from the
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. THE SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
DATED JULY 7, 2009 IS INCORPORATED BY REFERENCE.
Attes • J.
P othonotary
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