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09-6346
Madylene J. Rubendall N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- &316 CIVIL TERM Jereme J. Rubendall 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 Madylene J. Rubendall IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 6 3Y(, CIVIL TERM Jereme J. Rubendall Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is MQAM e - , who currently resides at 21?) key w" A cm Ii SIP P k nolS 2 Cumberland `County, Pennsylvania. I Lwho currently resides at Defendant is ye'rCWe -3- w&A 1559 Sixi nG ' oGd Car 11-sle- ?A M13 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 W. V? cAU26 at 5. The marriage is irretrievably broken, and the parties separated on 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. T24- 09 Date AnAithiii I Plai tiff, ro Se MnAll" - btA?i I, . q , verify that the statements made in this Complaint -U-" yJ are true and convect 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. 2y - n Date: Plai tiff, ®ro 4Se Assisted by: Jacqueline M. Verney, Esq. Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 OF- TH- p ,>OTARY 209 S EP 24 „h 10: 2 ! Madylene J. Rubendall Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 1,3WO CIVIL TERM Jereme J. Rubendall Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Madylene J. Rubendall, Plaintiff, to proceed in forma ap weris. 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. ?•V acq line M. Verney, Esquire Attorney for Plaintiff Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 ?Qdq SEA' 2? N Madylene J. Rubendall Plaintiff V. Jereme J. Rubendall Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- b 34to CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, Jereme J. Rubendall (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. 9 - a,? -©g Date J e J. Ru dall, Defendant -: RL 1. : I °s uL- OF THE 2009 SE 25 N 10. 5--J