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HomeMy WebLinkAbout09-74890- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIDGET F. EMEIGH, CASE NO. 9 _ y C V. : JASON T. EMEIGH, : CIVIL ACTION -LAW Defendant : IN DIVORCE NOTICE TO DEFENDANT 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 in 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 Defendant. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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 at the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 South Bedford S et Carlisle, PA 17 Telephone (717) W-3166 Sheri W Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 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. BY THE COURT: Date: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIDGET F. EMEIGH, CASE NO. 69--7 ?N V. JASON T. EMEIGH, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Bridget F. Emeigh who currently resides at 705 Stanwix Circle, Apt. 1, Carlisle, PA 17013. 2. Defendant is Jason T. Emeigh, who currently resides at 465 Wolf Bridge Road, Carlisle, PA 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on September 4, 1999. 5. Plaintiff and Defendant separated on November 1, 2008. 6. There have been no prior actions commenced for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. Plaintiff has been advised of counseling and that she may have the right to request the Court to require the parties to participate in counseling. 7. Plaintiff avers that no issues regarding the custody of children result from this action. COUNT 1 3301(c) IRRETRIEVABLE BREAKDOWN 8. Paragraphs 1 through 7 are incorporated herein by reference. 9. The marriage is irretrievably broken and the parties are estranged due to marital difficulties with no reasonable expectation of reconciliation. 10. Plaintiff requests the Court to enter a decree in divorce. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order dissolving the marriage between the parties. Respectfully submitted, Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIDGET F. EMEIGH, V. JASON T. EMEIGH, Defendant : CASE NO. : CIVIL ACTION -LAW : IN DIVORCE VERIFICATION I, Bridget F. Emeigh hereby state that I am the plaintiff in the foregoing action and that the facts contained herein are true, correct and accurate to the best of my knowledge, information and belief. I further understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. ?D Bridget F. Emeigh D Date: `u Z°l CA r? PLED- a - , OF f THE pp,,)Tf-!ONOTARY 2009 OCT 29 PM 3: o l g'33?: ?o P??? c,&e 1-16:? '8' 0- 315 Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) BRIDGET F. EMEIGH, Plaintiff v. JASON T. EMEIGH, Defendant Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CA5E NO. 09-7489 DIVORCE AFFIDAVIT OF SERVICE I, Sheri D. Coover, Esquire hereby certify that I did serve a true and correct copy of the Complaint for Divorce upon the Defendant by depositing or causing to be deposited same in the U.S. mail certified, restricted delivery, postage prepaid on Jason Emeigh at Carlisle, Pennsylvania addressed as follows: Jason T. Emeigh 465 Wolf Bridge Road Carlisle, PA 17013 Return card acknowledging receipt on 11/13/2009 is attached as Exhibit "A". submitted, Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) Attorney for Plaintiff BRIDGET F. EMEIGH, Plaintiff v. JASON T. EMEIGH, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. 09-7489 DIVORCE Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 16th day of November, 2009, I caused the foregoing AFFIDAVIT OF SERVICE to be served upon Defendant via United States First Class Mail addressed as follows: Jason T. Emeigh 465Wo1f Bridge Road Carlisle, PA 17013 submitted, Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 ~, ^ 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: cv~~ n i F~~~~ A. Signature ^ ggent X ~ ^ Addre C. Date of Del g, ceived by (Printed Nam D. Is delivery address different from item 1? ^ Yes If YES, enter delivery address below: ^ No ~ 3, ice Type t ~1 ~ ~~G I _~ Certified Mail ^ Express Mai{- . _. ~~~ 11 \-1 ~ ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D_ - ^ Yes 4. Restricted Delivery?. (Extra Feej 2. Article Number 709 141 ~0~~ 119d X3[]6- (Transfer from service label) to25ss-o2-M-~sa Domestic Return Receipt PS Form 3811, February 2004 ~X ~ . /i ~1 L~ ~tll~, f~...~ 1 .. ~l t ~ .3 C:,_; . ~ . ;::' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIDGET EMEIGH . V. JASON T. EMEIGH NO. 09-7489 DIVORCE DECREE AND NOW, X1.29 ~~ Z'i Z~ [ ~, it is ordered and decreed that BRIDGET EMEIGH plaintiff, and JASON T. EMEIGH ,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. Rv the ~n~ in 3 ~ a~ ~ ~ a ~-~. ~ m~t~d .~, ~ e_-~- ~",~ ~ao~