HomeMy WebLinkAbout09-6000G
STACEY PARNELL, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 01- WOO
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or (800) 990-9108
BY P
Stacey melt, Plaintiff
V.
CIVIL ACTION - LAW
ROBERT L. PARNELL, JR., IN DIVORCE
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 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.
Dated:
STACEY PARNELL, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO.
V. :
CIVIL ACTION - LAW
ROBERT L. PARNELL, JR., IN DIVORCE
Defendant
COMPLAINT
AND NOW comes Plaintiff, Stacey Parnell, pro se, and files the following Complaint
in Divorce.
COUNTI
Divorce Under 3301(c) or 3301(d) of the Divorce Code
1. Plaintiff is Stacey Parnell, who currently resides at 12B Richland Lane, Apt.
T8, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. Defendant is Robert L. Parnell, Jr., who currently resides at 510 W.
Cumberland Road, Enola, Cumberland County, Pennsylvania, 17025.
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 October 30, 2004 in Enola,
Pennsylvania.
5. Plainfi f and Defendant were separated on August 18, 2007. 1
6. There have been no prior actions of divorce or for annulment between the
parties.
7. The marriage is irretrievably broken.
2
s
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, Stacey Parnell, respectfully requests the Court to enter a
decree of divorce under Section 3301(c) or (d) of the Divorce Code.
B
Stacey melt, Plaintiff
Dated:
3
VERIFICATION
Subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unswom falsification to
authorities, I hereby certify that the facts set forth in the foregoing document are true and
correct to the best of my information and belief.
Stacey Pa t
Dated: ? t 4 , 2009
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DC, 9 SE'P -G i`i'i c.• 30
CLati _ y
Id. 40. 50 ?'/f?
STACEY PARNELL, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. fig- ?6OG
v.
CIVIL ACTION - LAW
ROBERT L. PARNELL, JR., IN DIVORCE
Defendant
AFFIDAVIT OF ACCEPTANCE OF SERVICE
I hereby accept service of the Complaint in the above matter.
411"
Robert L. Parnell, Jr.
Dated: 91a 19
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