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HomeMy WebLinkAbout09-8004 to. David E. Chastain Plaintiff V. Louise S. Chastain Defendant N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.09- qb0y IN DIVORCE 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 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, 1 Courthouse Square, 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 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 -Op. David E. Chastain IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- ';f'Q Q y CIVIL TERM Louise S. Chastain Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is a,U J'61 F C h aS "f 0. t`n , who currently resides at I8'37 cWo /A.A Ao-fforn. kol /V e u? v,'llt. /a- /76+0.x// , Cumberland County, Pennsylvania. 2. Defendant is 9 nAas ?Gt,t v, , who currently resides at tfl'(. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on 09- - OS' - / Q Q 9 at 13ex ('d n. % n . 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment, between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. .Ip 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Plaintiff, Pro Se I, Da.a d C CX as ia,i ?t , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unswom falsification to authorities as provided in 18 Pa. C.S. §4904. //-/f0-o9 Date: Plaintiff, Pro Se Assisted by: Tabetha A. Tanner, Esq. Tanner Law Offices 1300 Market St., Suite 6 Lemoyne, PA 17043 (717) 731-8114 OF THE j?&40NTW 2009 NOY 18 AM 10= 14 =}JUNTY PE"'INSYLVANIA ,ik -;r F/.o David E. Chastain IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 4o0q ' CIVIL TERM Louise S. Chastain Defendant IN DIVORCE ? ? Z :.7 ' o -? cn } ao PRAECIPE TO PROCEED IN FORMA PAUPERIS ?c o To the Prothonotary: z Kindly allow, David E. Chastain, Plaintiff, to proceed in forma au ris. I, Tabetha A. Tanner, attorney for the party proceeding in forma pa uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. y&& A-Iazaa Tabetha A. Tannerney, Esquire Attorney for Plaintiff Tanner Law Offices 1300 Market St., Suite j( /O Lemoyne, PA 17043 (717) 731-8114 David E. Chastain Plaintiff V. : Louise S. Chastain Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 4 OW CIVIL TERM IN DIVORCE 0 ..o M' o V> C* yy ? ; Z? 3 NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID E. CHASTAIN V. LOUISE S. CHASTAIN ~JO, 09-8004 CIVIL TERM DIVORCE DECREE AND NOW, ,~~~rc~ ~~ a~~~ , it is ordered and decreed that DAVID E. CHASTAIN ,plaintiff, and LOUISE S. CHASTAIN ,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, ~~~~~~o 3.ay~~o c~-+. ~P~ ~ afi, ~~ rnoulec~ -~ rne~;\er~ `~' ~--~ 1 c~nn-er~e~ `~ ~-~ .