Loading...
HomeMy WebLinkAbout09-6491Johnson, Duffle, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 ANGELA M. DUNN, Plaintiff V. KEVIN J. DUNN, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS IN DIVORCE 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 pages 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 the 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, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Oq -(gq91 0-,-tyil T?Pxk CIVIL ACTION - LAW Johnson, Duffle, Stewart & Weidner By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 ANGELA M. DUNN, Plaintiff V. KEVIN J. DUNN, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 4- G v 9/.? tc.w? CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(CO OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Angela M. Dunn, by and through her attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Kevin J. Dunn: 1. The Plaintiff is Angela M. Dunn, an adult individual, residing at 601 Rupley Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Kevin J. Dunn, an adult individual, residing at 730 C Tower Road, Enola, Cumberland County, Pennsylvania 17025. 3. The Plaintiff and Defendant were married on May 13, 2009, in Yosemite National Park, California. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties separated no later than August 1, 2009. 8. The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a Decree of Divorce under Section 3301(c) or 3301(d) of the Divorce Code. JOHNSON, DUFFIE, STEWART & WEIDNER By: :377409 VERIFICATION I, ANGELA M. DUNN, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unswom falsification to authorities. Date: 4 (0 9 gela M. Dunn 'f? , A cy Z(?` ET 25 V?kl 0-60,6a PO A" I ?,? 3?3(v5 ex?' a3?oR3 Johnson, Duffle, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 ANGELA M. DUNN, Plaintiff V. KEVIN J. DUNN, Defendant AFFIDAVIT IN DIVORCE ANGELA M. DUNN, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: 9? G to 9 A GELA M. DU Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. N - l04Q I ctvi I (fermi CIVIL ACTION - LAW 0 S-EP 25 f:.' -,? 2: 3 US tr4?AO?, ? ^`1l ?' s , ANGELA M. DUNN, v. KEVIN J. DUNN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. CIVIL ACTION - LAW : IN DIVORCE Defendant : NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff, ANGELA M. DUNN, in the above matter hereby elects to resume and hereafter use the previous maiden name of ANGELA M. SWARTZ, and gives this written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, P.L. 1309 No. 295, §702; 54 Pa.C.S.A. 704, as amended. ?rl a't-? A GELA UNN TO BE KNOWN AS: 0"t'? tM ANGELA SWARTZ 'r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. On this, the S day of 2009, before me, a notary public, personally appeared ANGELA M. DUNN to be known as ANGELA M. SWARTZ, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. :377683 a Notary Pub c <o E ovr?< S, 7?r 4 'pnd County My -7itl1 c '! C p}t 7 X4434 3:7 2G11 RID- Ot"FICE OF THE RO?i NITAAk 2009 OCT -5 PH 3: 14 Pt"'NNSYLVA M 411 • oco P a ATry CO 31441 1 a314f,4 Johnson, Duffle, Stewart & Weidner By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff ANGELA M. DUNN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff D ?_ 0 q NO. V. KEVIN J. DUNN, Defendant ACCEPTANCE OF SERVICE CIVIL ACTION - LAW IN DIVORCE I, KEVIN J. DUNN, hereby accept service and acknowledge receipt of the Complaint in Divorce filed on.,AQh 14," aS 2 , 2009 by the Plaintiff in the above-captioned divorce action. ©? ?..: S U Date: KEVIN J. DUNN 378427 ALM-OFFIGE OF THE PROTHONOTARY 2009 OCT 27 PM 12: 4 5 CUm'L.r Ilii _, 4 ,su U.A, UNTY PFNNGYLVAN!A