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HomeMy WebLinkAbout09-8627w LISSA K. CHANDLER, Plaintiff V. BUEL E. CHANDLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 'nQ- e(0 2t7 L cj (., CIVIL ACTION - LAW 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 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, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6100 r I& LISSA K. CHANDLER, Plaintiff V. BUEL E. CHANDLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: D 1?- T4.27 et -7?zc^- CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Lissa K. Chandler, who currently resides at 261 Barnstable Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is :Buel E. Chandler, who currently resides at 261 Barnstable Road, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 29, 1986. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Divorce is sought pursuant to the provisions of the Divorce Code, Sections 3301(c), and 3301(d), in that the marriage is irretrievably broke. 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 such counseling. 8. Plaintiff does not request counseling, pursuant to §§3301(c) and 3301(d) of the Divorce Code. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, Date: By: Arf&ew H. Shaw, Esquire Sup. Ct. ID No.: 87371 200 S. Spring Garden St., Ste. 11 Carlisle, PA 17013 (717) 243-7135 (717) 243-7872 (facsimile) Attorney for Plaintiff t VERIFICATION I, Lissa K. Chandler, 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date: Lissa K. Chandler R E - - THE " pY LQ99 O'C 15 ? i 2: 25 dx?if 7sa-) R' e7?6 s-? A LISSA K. CHANDLER, Plaintiff' V. BUEL E. CHANDLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 09-8627 CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE I, Andrew H. Shaw, Counsel for the Plaintiff, Lissa K. Chandler, hereby certify that a true and correct copy of the Divorce Complaint in the above captioned case was served upon Defendant via certified mail, restricted delivery, on December 23, 2009. A copy of the signed certified receipt is attached. Date: Andrew fl. Shaw, Esquire PA Sup. Ct. ID Num. 87371 200 S. Spring Garden St., Suite 11 Carlisle, PA 17013 717-243-7135 Counsel for Plaintiff Y ? A. X B. eceive`d by (fWW Name) -? C D?O of Del C. l D. Is delivery address dl%w, from 6m 1 If YES, eater delivery address belo LMW!PX F' i t- ( r 3. Type CMtifled Ma8 0 Express Mail 0 Registered 0 Retum Receipt for Merchandise 0 insured mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. 7009 2250 0002 8246 1091 (MMfor from service Abso PS Form 3811, February 2004 Domestic Retum Receipt 102595-02-M-1540 ¦ Complete Items 1, 2, and 3. / Jso complete Item 4 If Restricted Delivery 4 desired. ¦ Print your name and address !on the reverse so that we can return the card to you. ¦ Attach this, ud to the back of the mailpiece, or on the fibnt_If space permits. 1. Article Addressed to: 2099 DEC ft LISSA K. CHANDLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, No.: 09-862 i CIVIL ACTION -LAW ce.; BUEL E. CHANDLER, ~? ~~_ "' Defendant --~~~ "~ ~ -:~ IN DIVORCE r~~ c`~a~ f''r=- '~7 ~'" r- c:,o ~ L '-' STATEMENT OF INTENTION TO PROCEED _~ _...,,~, s'-" '"'- ~ -r, - ..~:~ A'' To the Col~rt: '~" `~'~' .._. ' C~ w Plaintiff, L,issa K. Chandler, intends to proceed with the above-captioned matter. ~~ Date: ~- - ~~ ~ ~ ~~-~ ~ ~~ ~ --- A drew H. ~ haw., Esquire PA Sup. Ct. ID Num. 87371 200 S. Spring Garden St., Suite. 1 1. Carlisle, PA 17013 717-243-7135 Counsel for Plaintiff