HomeMy WebLinkAbout09-6331THOMAS G. SEELY,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
LYNNAYA M. SEELY,
Defendant
No. 0,7- &331 Clri l
NOTICE TO DEFEND AND CLAIM RIGHTS
TO: LYNNAYA M. SEELY, 403 Georgetown Road, Mechanicsburg, Cumberland
County, Pennsylvania.
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 Plaintiff. You may lose money or property rights'or
other rights important to you, including custody or visitation of your children.
When the grounds for the divorce is indignities or an irretrievable breakdown of
the marriage, you may request marriage counseling. The 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,
LAWYERS FEES OR EXPENSES BEFORE DIVORCE 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 HERE YOU CAN GET LEGAL HELP.
Mid-Penn Legal Services
401 East Louther Street, Suite 103
Carlisle, PA 17013
(717) 243-9400
www.midpenn.org
THOMAS G. SEELY
THOMAS G. SEELY, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
LYNNAYA M. SEELY, No. O ?- 6 3 31 cam:1
Defendant
NOTICE OF AVAILABILITY OF COUNSELING
Whenever indignities, irretrievable breakdown with either mutual consent or after
a year of separation are the grounds for divorce under Section 3301 (a), (b), (c) or (d) of
the Divorce Code, counseling may be available to the parties upon request.
Upon request, the court will provide parties to this action with a list of qualified
professionals who provide such counseling services. Should the court require
counseling sessions, the choice of a qualified professional shall be at the option of the
parties, and such professional need not be selected from a list provided by the court.
Should you desire a list of qualified professionals to provide counseling services,
contact your attorney or the Office of the Prothonotary, 1 Court House Square, #100,
Carlisle, Pennsylvania, telephone (717) 240-6195.
THOMAS G.
THOMAS G. SEELY,
Plaintiff
V.
LYNNAYA M. SEELY,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
No. D'S 6 33 I Gam- I
PRO SE COMPLAINT UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE
PLEASE TAKE NOTICE this d day of 2009, that
THOMAS G. SEELY, pro se, files this Complaint in Divorce and represents as follows:
1. Plaintiff THOMAS G. SEELY maintains a home of record at 403 Georgetown
Road, Mechanicsburg, Cumberland County, Pennsylvania. He is currently on Federal
Title 10 active duty with the 28th Combat Aviation Brigade deployed to Iraq.
2. Defendant LYNNAYA M. SEELY presently resides at 403 Georgetown
Road, Mechanicsburg, Cumberland County, Pennsylvania.
3. The parties have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately preceding the filing of this
Complaint.
4. The parties married on July 28, 2006, in Cumberland County, Pennsylvania.
5. There are no children born to this couple.
6. There have been no previous actions of divorce or for annulment between the
parties.
7. The marriage is irretrievably broken.
8. Plaintiff is afforded the opportunity to participate in counseling at his active
duty station and is aware that he has the right to request that the Court require the
parties to participate in counseling.
9. Plaintiff requests this Honorable Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff THOMAS G. SEELY, requests this Honorable Court to
enter a decree to divorce the parties from the bonds of marriage.
Respectfully submitted,
SGT THOMAS G.
28th Combat Aviation Brigade
Pennsylvania Army National Guard
Camp Adder, Iraq
F 711E Y
2009 SEP 23 Cif I ? a
CUM ; .
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THOMAS G. SEELY, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
LYNNAYA M. SEELY, No. 0 l
Defendant
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint with the Notice to Defend and Claim Rights.
Mechanisburg, PA 17050
,-),, 2
Date of Receipt: /
403 Georgetown Road
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2009 SEP 23 IF 1 a
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