HomeMy WebLinkAbout09-7540
ROY A. KESSLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2009 - 7-/0 CIVIL TERM
LISA J. KESSLER, CIVIL ACTION-LAW
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 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 at the Cumberland County Court House,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. 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
%
ROY A. KESSLER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2009 - 75vo CIVIL TERM
LISA J. KESSLER, CIVIL ACTION-LAW
Defendant IN DIVORCE
DIVORCE COMPLAINT
1. Plaintiff is Roy A. Kessler, an adult individual who currently resides at 353
Richland Road, Carlisle, Cumberland County, Pennsylvania 17015.
2. Defendant is Lisa J. Kessler, an adult individual who currently resides at
353 Richland Road, Carlisle, Cumberland County, Pennsylvania 17015.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on June 2, 1984 in Carlisle,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability of counseling and that he
may have the right to request that the court require the parties to participate in
counseling.
8. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in
favor of the Plaintiff and against the Defendant.
COUNT II -EQUITABLE DISTRIBUTION
9. Plaintiff hereby incorporates by reference paragraphs 1 through 8 above.
10. The parties have acquired real estate, personal property, including
automobiles, bank accounts and other items of miscellaneous property during the
course of their marriage, some of which is marital property.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
decree which effects an equitable distribution of marital property.
Respectfully submitted,
Date: /O . Z?
O'BRIEN, BARIC & SCHERER
A-",-
Wc6ael A. Scherer, Esquire
I. D.# 61974
19 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff
mas.d it/domestic/kessler/d ivorcecom plaint.pld
VERIFICATION
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.
Date: 1,9 I8 -6
oy A. Kessler
OF ?HEP'?' NP 116TARY
1104 OCT 30 Ph 2: 22
CU, ?`riV`?iL}15aJN?
??uvU
? 11,6*
-J/ el