The URL can be used to link to this page

Home My WebLink About09-6347k. ill. Nicolle M. Brougher-Smith Plaintiff V. Andrew P. Smith Defendant N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 3Y7 CIVIL TERM 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 Nicolle M. Brougher-Smith Plaintiff V. Andrew P. Smith Defendant 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 6 3y7 CIVIL TERM IN DIVORCE Cumberland County, Pennsylvania. 2. Defendant is 112 ?Y'P,j V! <52'VUt4AX , who currently resides at P'z' "701-3 oi"=6a -Egixi baumar&OAC"I "701-3 - L"k"& 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 _ Acx, it* a,Dl)3 1A 1 %43 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. COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE Plaintiff is W 1 MAe. M WIC'- ?{`I ( n, who currently resides at . 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. q ask M -zy Date Plaint f, Pro Se I, N)V&o MC41-h 1 ?nverify 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. QWW Date: Pl 'ntiff, Pro Se Assisted by: Jacqueline M. Verney, Esq. Law Office of Jacqueline M. Verney 44 S. Hanover Street Carlisle, PA 17013 (717) 243-9190 ??I 'rl '?t^,i t' i jA u; t„ ?.. w; ,, ,; s;:s ?? Nicolle M. Brougher-Smith IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 4e 3 q7 CIVIL TERM Andrew P. Smith Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Nicolle M. Brougher-Smith, Plaintiff, to proceed in forma 12auRLns. 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- /VI.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 of Ztl 9 SE P ?t Ail fc,: 22 + Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NICOLLE M. BROUGHER-SMITH, N0.09-6347 Plaintiff CIVIL TERM v. ANDREW P. SMITH, IN DIVORCE Defendant DEFENDANT'S COUNTER-AFFIDAVIT UNDER §33010 OF THE DIVORCE CODE 1. I oppose the entry of a divorce decree because: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. I wish to claim economic relief which may include alimony, division of property, lawyer s fees or expenses or other important rights. I understand that in addition to the foregoing statement, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. r October 2, 2009 Peter B. Foster, Esquire Attorney for Defendant 114 South Street Harrisburg, PA 17101 717-234-9321 I.D. #15357 Y VERIFICATION I hereby verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, unsworn falsification to authorities. October 2, 2009 Andrew P. Smith ~ r CERTIFICATE OF SERVICE I hereby certify that on this date, October 2, 2009, I served a copy of the foregoing Counter Affidavit on the Plaintiff by mailing said copy by first class mail at Harrisburg, PA, to the attorney for Plaintiff at the following address: Jacqueline M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 October 2, 2009 Peter B. Foster, Esquire Attorney for Defendant FlLEt3-~t=~IC~ OF ~-ic ; '~'7~-0~~7T~Y 1009 QC3 -2 PM 3~ 3Q r's-f~"~iS,21r'n~Ju~