Loading...
HomeMy WebLinkAbout09-6343 Laura R. Mackey N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- W%3 CIVIL TERM Christopher L. Mackey Defendant 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 Laura R. Mackey IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- G 3 Y 3 CIVIL TERM Christopher L. Mackey Defendant IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is L(rcL 9 Mq I-e , who currently resides at /Lob C ,M. E N A vi Iif IAA 1 -7aL4 I Cumberland County, Pennsylvania. 2. Defendant is who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on 1 I aon I at Cc.?lisl? PA 5. The marriage is irretrievably broken, and the parties separated on q 1Q)a(r-7 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. 6 Date P ntiff, Pro Se I, _ i a rem , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: hintiff, Pro S9 I Assisted by: Jacqueline M. Verney, Esq. Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 .. II IL i F J7a ICIN(IITAPY 2009 S'P 24 AH 10: 21 Laura R. Mackey IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 4,3143 CIVIL TERM Christopher L. Mackey Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Laura R. Mackey, Plaintiff, to proceed in forma au ris. I, Jacqueline M. Verney, attorney for the party proceeding in forma au ris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. acq line M. Verney, Esquire Attorney for Plaintiff Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 THE 2009 SEP 24 6 `= 20 Laura R. Mackey IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.09- 6 343 CIVIL TERM Christopher L. Mackey Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Christopher L. Mackey (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. N?(-W ?WA - Christ pher LOOKlackey, Defendant rr. w: OF THE* 2009 SE P 25tai 10: r.