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HomeMy WebLinkAbout09-7397DAVID ANDERSON, Plaintiff vs. DEBRA K. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 01- 7397 Civil Term ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 94 DAVID ANDERSON, Plaintiff vs. DEBRA K. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09. 7,397 Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is David Anderson, a competent adult individual, who resides at 106 Channel Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Debra K. Anderson, a competent adult individual, who resides at 106 Channel Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on July 12, 1985 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. David Anderson, Plaintiff Respectfully submitted, ol?/v9 Date/ J e Adams, Esquire . . No. 79465 West South St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF D PLE PD ?r ICE OF TH rOTARY 2099 OCT 28 Aft 9: 34 P N+?SYNAW 4, &tq x338, 50 G2 S'39(p OCu.. -7.3 2 6 S -;?- DAVID ANDERSON, Plaintiff vs. DEBRA K. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09 - 7397 Civil Term ACTION IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on November 5. 2009 I served a true and correct copy of the NOTICE TO DEFEND and DIVORCE COMPLAINT, in the above-captioned matter upon the following individual(s) by certified mail, restricted, return receipt requested, addressed as follows: Debra K. Anderson 106 Channel Drive Carlisle, Pa. 17013 DEFENDANT ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ~~~~ A. X ^ Agent . He ived b (Pri ed N me) C. Date of Delivery 'So D. Is delivery address different from item 1? ^ Yes If YES, enter delivery address below: ^ No 1, n ~ ~~~~ ~~~ ~ 13. Service Type /^/~/1 l~~ en~ I ^ I~ t9 Certified Mail ^ Express Mail (` IV -ylr /)~ ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Feel ~ Yes 2. Article Number 7009 X820 0~~1 0749 1233 (fiansfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Respectfully Submitted: n Adams, Esquire .D No. 79465 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~l~~r ., :~~c t~f _ ., , , ~ltED-OEFIC~ 0~ THE P~OTNrJN©i'ARY 2~110CT 23 PP9 3= C 4 CU pENNSY YAN ~ TY DAVID ANDERSON, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs No. 09 - 7397 Civil Term DEBRA K. ANDERSON, :ACTION IN DIVORCE Defendant STATEMENT OF INTENTION TO PROCEED TO THE PROTHONOTARY: Plaintiff, David Anderson, intends to proceed with the above-captioned matter. Please ren ove this case from the termination list. Respectfully Submitted, Date:~~' t~ ~ - ~ ~ ,~ } ~ ~~ J e Adams, Esquire ~~ W. South St. Carlisle, Pa. 17013. (717) 245-8508 ATTORNEY FOR PLAINTIFF