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HomeMy WebLinkAbout09-5595COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN M. BURKEY Plaintiff Civil Action-Divorce V. Docket No. JERRY R. BURKEY Defendant 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 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 divorce is irretrievable breakdown of the marriage, you may request 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, go to or telephone the office set forth below. This office can provide you with information about hiring a lawyer. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. Legal Services of Central Pennsylvania 2113A N. Front Street Harrisburg, PA 17111 (717) 232-0581 -kmbe rla Cbuh ? l??r Ass Cl I oyl 3 a s_ g?c6 s? Car (i S1 e , P Y?? 11013 t' -7 1-1? oaq q - Z I t.P Zo COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE CUMBERLAND COUNTY, PENNSYLVANIA KRISTEN M. BURKEY Plaintiff Civil Action-Divorce V. Docket No. 09- .SS 4 S CLU JERRY R. BURKEY Defendant COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Kristen Marie Burkey, who currently resides at 2203 Fenwick Avenue, Mechanicsburg, Cumberland County, Pennsylvania since December 5, 2008. 2. Defendant is Jerry Ray Burkey, who currently resides at 522 W. Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania since July 1, 2009. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on August 31, 2007 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requires the court to enter a decree of divorce. 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 unworn falsification to authorities. Plaintiff 2CJ9 AU Go 1 1 [ 1. 11 3,': Gv ?d . -W33F - SD 101- ( ?r./J' ? ?/loss= .s"7aO /7657,V - 3 ?GY