HomeMy WebLinkAbout09-5701DAVID PAUL MARTIN
Plaintiff
V.
KRIS ANN MARTIN,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 09 - S 7 01 (_
CIVIL ACTION-LAW
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 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 of 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 counseling. A list of marriage counselors is available at the
Office of the Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEED OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GTRANTED, 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 or 800-990-9108
DAVID PAUL MAR N
PLAINTIF
PRO SE
DAVID PAUL MARTIN:
Plaintiff
V.
KRIS ANN MARTIN,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 09 r 701 ca.i: I
CIVIL ACTION-LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
AND NOW COMES the above-named Plaintiff, by Joanne Marino McGreevy,
Esquire, and seeks to obtain a Divorce from the above-named Defendant upon the
grounds hereinafter set forth:
1. Plaintiff, DAVID PAUL MARTIN, an adult individual who is sui juris and
resides at 205 Linda Drive, Mechanicsburg, PA 17055.
2. Defendant is KRIS ANN MARTIN, who is sui juris and resides at 205 Linda
Drive, Mechanicsburg, PA 17055.
3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania
for at least six (6) months immediately previous to the filing of this complaint.
4. Defendant has been a bona fide resident in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of
this complaint.
5. The Plaintiff and Defendant were married November 19, 1977, in
Mechanicsburg, Cumberland County, Pennsylvania.
6. There have been no prior actions of divorce or for annulment between the
parties.
7. Plaintiff has been advised of the availability of counseling and the right to
request that the court require the parties to participate in counseling.
8. The Defendant is not currently member of the armed services of the United
States or any of its allies.
COUNT I, REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301
(c) OF THE DIVORCE CODE
9. The Plaintiff avers that the ground on which the action is based is that the
marriage is irretrievably broken.
10. After ninety (90) days from the date of 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.
WHEREFORE, IF BOTH PARTIES FILE AFFIDAVITS CONSENTING TO A
DIVORCE AFTER NINETY (90) DAYS HAVE ELAPSED FROM THE
FILING OF THIS COMPLAINT, PLAINTIFF RESPECTFULLY REQUESTS
THE COURT TO ENTER A DECREE OF DIVORCE PURSUANT TO
SECTION 3301(c) OF THE DIVORCE CODE n
DATE_ V S 1" i
DAVID PAUL MARTXN
PLAINTIFF
PRO SE
205 Linda Drive
Mechanicsburg, PA 17055
DAVID PAUL MARTIN,
Plaintiff
V.
KRIS ANN MARTIN
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
:NO. 09 -- 5-10 (c r r
CIVIL ACTION-LAW
IN DIVORCE
VERIFICATION
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 unsworn falsification to authorities.
DATE 8 /-) o
r
DAVID PAUL MART
PLAINTIFF
R ritac
OF THE MT OTARY
2009 AUG 18 Ali I1: 50
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PENNS? YLVAN A
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