HomeMy WebLinkAbout09-65044 V
PAUL D. SCHMECK,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
JANE R. SCHMECK, :NO. Of, lo.S? CIVIL TERM
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
will proceed without you and a decree of divorce or annulment may be entered against you for
any 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 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 Cumberland County Courthouse, Carlisle, Cumberland County,
Pennsylvania, 17013
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, Pennsylvania 17013
Phone: (717) 249-3166 or (800) 990-9108
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PAUL D. SCHMECK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
JANE R. SCHMECK, : NO. t9q - 4,50 Y CIVIL TERM
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
NO FAULT
1. Plaintiff is Paul D. Schmeck, an adult individual currently residing at 21 Winchester
Gardens, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Jane R. Schmeck, an adult individual currently residing at 5 Maple
Avenue, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on May 18, 1974, in Berks County,
Pennsylvania.
5. There have been no other prior actions for divorce or annulment between the parties.
6. Neither the Plaintiff nor the Defendant are members of the United States 'Armed
Forces or its Allies.
ek 40
7. Plaintiff has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in counseling. Knowing this, Plaintiff does
not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90)
days from the date of service of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23
P.S. Section 3301 (c) of the Domestic Relations Code.
Respectfully submitted,
N D n 0.n r, - A e? . ?r10 n
Hannah Herman Snyder, Esquire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unworn falsifications to authorities.
DATE:
PAUL D. CHMECK, Plaintiff
il rr? r
2009 SEE 28 P 42: U
rs?' Lr:
PAUL D. SCHMECK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION -LAW
JANE R. SCHMECK, NO. 2009-6504 CIVIL TERM
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, Michael A. Scherer, Esquire acknowledge that on
I received a
Complaint in Divorce in the above captioned action and acknowledge that I am authorized to do
so on behalf of the Defendant, Jane R. Schmeck.
Date: I, ?, 0 ?. "W AA_:?
Michael A. Scherer, Esquire
Attorney for Defendant
O'Brien, Baric & Scherer
19 West South Street
Carlisle, PA 17013
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OF THE 7APY
2009 OCT -7 AM 9: 52