Loading...
HomeMy WebLinkAbout09-6786JOSEPH HENRY FISHER, JR., Plaintiff V. JERI LYNN FISHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE :NO. ?N-(0796 CIVIL TERM 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 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, Cumberland County Courthouse, 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, 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 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JOSEPH HENRY FISHER, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE JERI LYNN FISHER, Defendant : NO. CIVIL TERM DIVORCE COMPLAINT The plaintiff, Joseph Henry Fisher, Jr., by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. §M3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Joseph Henry Fisher, Jr. , who currently resides at 1349 Grandview Court Carlisle, Cumberland County, Pennsylvania 17013, since approximately February 13, 2007. 2. Defendant is Jeri Lynn Fisher, who currently resides at 500 Mountain Road, Marysville, Perry County, Pennsylvania 17053, since approximately February 2009. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on February 14, 2001 at Elizabethville, Dauphin County, Pennsylvania. Plaintiff and Defendant have lived separate and apart since September 13, 2008. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. arah Molle Certified Legal Intern A ONAL Superv ing Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date ?() - 1'3 - O Plaintiffs seph Henry Fisher, J FILED-Of-FICE ('T THIE' 2009 OCT 13 P;l 12: 38 JOSEPH HENRY FISHER, JR., Plaintiff V. JERI LYNN FISHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 09" rv_Nw CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Joseph Henry Fisher, Jr., Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date?i? /.? Respectfully submitted, Sarah Mollett Certified Legal Intern ROB INS THOM M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 FILEL -; ICE OF T?ilc- 2009 OCT 13 PM 12: 38 cuj JOSEPH HENRY FISHER, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE JERI LYNN FISHER, Defendant : NO. 09 - Lv'i8 (o CIVIL TERM ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint on behalf of my client Jeri Lynn Fisher. Date /0•/ S 7? a, ??A Michael O. Palermo, q. Rominger & Associate 155 S. Hanover Street Carlisle, PA 17013 2089 O" T 1 5 PH 3: 26 0.J' iA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Joseph H. Fisher, Jr. . V. Jeri Fisher N O. 09-6786 DIVORCE DECREE AND NOW, F c.~c~~or~ ~3 ~,01~ , it is ordered and decreed that Joseph H. Fisher, Jr. plaintiff, and Jeri Fisher ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By the Court, Attest: Prothonotary is yr~ ~~~ ~ l