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HomeMy WebLinkAbout09-7796Pamela L. Purdy Attorney ID No. 85783 308 N. Second Street, Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff CHRISTOPHER W. WHITSON, Plaintiff V. MELANIE D. WHITSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. OQ- '779(v Civilrlerm : 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 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 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 Courthouse, Carlisle, PA. 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 4?WOU2 Lpw-'?Z? PAMELA L. PURDY ATTORNEY FOR PLAINTIFF Pamela L. Purdy Attorney ID No. 85783 308 N. Second St., Suite 200 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff CHRISTOPHER W. WHITSON, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 617- 7 9G - , - MELANIE D. WHITSON, Defendant IN DIVORCE COMPLAINT IN DIVORCE COUNT I Divorce Under 3301(c) or (d) of the Divorce Code 1. Plaintiff is Christopher W. Whitson who currently resides at 585 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Melanie D. Whitson who currently resides at 585 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 24, 2007 at Hardy, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Servicemembers' Civil Relief Act of 2004 and its amendments. 7. The marriage is irretrievably broken. 8. The grounds on which the action for divorce is based are: a. Section 3301(c): The marriage of the parties is irretrievably broken. After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce. b. Section 3301(d): The marriage of the parties is irretrievably broken. After two years from the date of separation, Plaintiff intends to file an Affidavit alleging that the parties have lived separate and apart for a period of two years and that the marriage is irretrievably broken, and he anticipates that Defendant will not deny that they parties have been separated for a period of at least two years and that the marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. WHEREFORE the Plaintiff requests this Court to enter a decree of divorce under Section 3301(c) or (d) of the Divorce Code. Respectfully submitted, 4tzt-(??? Pamela L. Purdy Attorney for Plaintiff Dated: N dVtw6-%-Lt, ?Y-,g VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: It 1q1o5 FILT Ci- Trig M19NOV10 A1c:0 $ 338. 50 po ATr4 ??X,-* (345 ?` a33a.81