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HomeMy WebLinkAbout09-8543'FAFILES\Clients\13678 DeSimoneU3678.1.DivCom Hubert X. Gilroy, Esquire I.D. 29943 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorney for Plaintiff ROBERT A. DeSIMONE, JR., Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009- er ll 1 ?Ym : CIVIL ACTION - LAW JESSICA L. DeSIMONE, 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. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. 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 Telephone (717) 249-3166 a ROBERT A. DeSIMONE, JR., Plaintiff V. JESSICA L. DeSIMONE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009- 6 C.c.in) : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Robert A. DeSimone, Jr., who currently resides at130 Sable Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jessica L. DeSimone who currently resides at 13 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on October 6, 2007, in Tennessee. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Member's Civil Relief Act. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. 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. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. When at the appropriate time, Plaintiff will file an affidavit stating that two years have expired from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301 of the Divorce Code. Date: 1-2-10-0? MARTSON LAW OFFICES B Y Hubert X. Gilroy, Es ire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorney for Plaintiff VERIFICATION The foregoing Divorce complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Divorce Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Q-V?A N Robert ASDeSimonne, r FAFILES\Clients\13678 DeSimone\13678.1.DivCom OTARY 2009 DEC I I AN 10: 18 sll?r s- ROBERT A. DESIMONE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. JESSICA L. DESIMONE NO. 2009-8543 DIVORCE DECREE AND NOW, ~ 3 ~b , it is ordered and decreed that ROBERT A. DESIMONE plaintiff, and JESSICA L. DESIMONE bonds of matrimony. defendant, are divorced from the 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 iart, t: J. Prot onotary • I y • l o Nc~ti cue. mo.~,12c~ -~.o A+t~ -b~ ~Xef-~ G; ~~o