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HomeMy WebLinkAbout09-5534Pamela L. Purdy Attorney ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff CATRINA M. HAMILTON-DRAGER, Plaintiff V. P. DANIEL DRAGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. aQ - ss3X (2, . ? L "--F&2-eyL 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, Carlisle, PA. 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 PAMELA L. PURDY ATTORNEY FOR PLAINTIFF r - • A. Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff CATRINA M. HAMILTON-DRAGER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. P. DANIEL DRAGER, Defendant NO. J 9- S5 3 y &icJ : IN DIVORCE COMPLAINT IN DIVORCE COUNTI Divorce Under 3301(c) of the Divorce Code 1. Plaintiff is Catrina M. Hamilton-Drager who currently resides at 3573 Ritner Highway, Newville, Cumberland County, Pennsylvania. 2. Defendant is P. Daniel Drager who currently resides at 305 Raymon Avenue, Boiling Springs, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 18, 2004 at Charlestown, New Hampshire. 14 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The grounds on which the action for divorce is based are: Section 3301(c): The marriage of the parties is irretrievably broken. After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce. 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. WHEREFORE the Plaintiff requests this Court to enter a decree of divorce under Section 3301(c) of the Divorce Code. Respectfully submitted, 4X4 4. pt"?? Pamela L. Purdy L-j Attorney for Plaintiff Dated: ... .4 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 unsworn falsification to authorities. Catrina M. Hamilton-Drager Dated: $ 4 01 ( 0) FI`?- :.Jf f 1? 1 200t9 AUG -1 Fil G: 1 J 13 3 S. 56 -?L 94y C K----O /29 G .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CATRINA HAMILTON-DRAGER ) Plaintiff ) V. ) P. DANIEL DRAGER, ) Defendant ) NO. 2009-CV-5534 CIVIL ACTION- LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Marylou Matas, Esquire, accept service of the Complaint in Divorce on behalf of P. Daniel Drager, the Defendant in the above-captioned action, and certify that I am authorized to do so. Date: 1 ?Z6 q _AA?(L I/a'z Mar atas, Es e Saidis, wer & Lindsay 26 West High Street Carlisle, PA 17013-2922 GE THE Pr'^ rTAY 2099 AUS' 26 Pf 12; CATRINA HAMILTON-DRAGER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2009-5534 CIVIL TERM P. DANIEL DRAGER, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed August 7, 2009. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filin,^J. and -er cf the r?:?'i p!aint. 3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn fal Date: j? Z4 DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERS 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court SAWIS, FLOWER & SAY 26 West High Street Carlisle, PA and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are nAe subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsifi lion to Date: 1112- 4 /0 9 P. FUu--Q!f-i 1VE ? "N',1 APY f TI c P ' ?? L 2009 N 0 V 25 Fil l : 16 t"L+ "`uOYI ?,rA,i"`".