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HomeMy WebLinkAbout09-8639Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JENNIFER L. MARKLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER D. MARKLEY, Defendant NO. 04,/ vi l 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 and visitation of your children. When the grounds for a 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 County Courthouse. 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, 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 I Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JENNIFER L. MARKLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER D. MARKLEY, Defendant NO. % S L 3 9 l ^- CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Jennifer L. Markley, an adult individual residing at 113 N. 34`x' Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Christopher D. Markley, an adult individual residing at 1525 N. Front Street, Unit 501, Harrisburg, Dauphin County, Pennsylvania 17102. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on September 7, 1985 in Grantham, Pennsylvania. 5. There are no children born of this marriage. 6. The parties separated on December 19, 2008. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9 of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Jennifer L. Markley, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; and B. Awarding other relief as the Court deems just and Dated: December 11, 2009 arbara Sump e- ullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 717 774-1445 JENNIFER L. MARKLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CHRISTOPHER D. MARKLEY, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unworn falsification to authorities. Dated: 12 NIFE L. MA EY Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 717 774-1445 JENNIFER L. MARKLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER D. MARKLEY, Defendant : NO. CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Jennifer L. Markley, hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: / 2 • //.,a INIFF# L. MARKLEY A Cr?_Pr•16 _,. ,c 2099 G C S) ;F' 5) 9 rl I , . 11 :' ;. Y Aw v . a&kaA V1 7 , ? 35-° 7y . z Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 JENNIFER L. MARKLEY, Plaintiff V. CHRISTOPHER D Defendant I, Barbara Sumple- Complaint in the IN THE COURT OF COMMON PLEAS AFFIDAVIT OF SERVICE CUMBERLAND COUNTY, PENNSYCVAW Q • "' TJ t? NO. 09 - 8639 rn : rv CIVIL ACTION - LAW .o IN DIVORCE'?- livan, Esquire, do hereby certify that I served a copy of the Divorce matter by United States Mail, Restricted Delivery, Certified No. 7007 2680 0002 4649 5475, Return Receipt Requested, on the above-named Defendant, Mr. Christopher D. Markley, on December 21, 2009 at 10:50 a.m. at Defendant's last known address: 1525 N. Front Street, Unit 50 , Harrisburg, Pennsylvania 17102. The original certified mail receipt is attached as Exhibit `A." The original return receipt card was never returned to my office. I have been able to obtain from the New Cumberland Post Office confirmation said certified restricted delivery le ter was received and signed for by the above named Defendant, Mr. Christopher D. Markley. A copy of the confirmation and scanned signature image are attached hereto as Exhibit "A'. I hereby certify that t be facts set forth above are true and correct to the best of my knowledge, information and elief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: March 19, 2010 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff USPS - Track & Confirm http://trkcnfrml.smi.usps.com/PTSIntemetWeb/InterLabellnquiry.d... e Home I Help I Sian in ---- ----- ------ - ------ -- -- Track & Confirm FAQs `track. & Confirm Search Result Label/Receipt Number. 7007 680 0002 4649 5475 ?. _ _-- Class: First-Class Maile Track & Cm fm Service(s): Certified Mail Enter Label/Receipt Number. Retum Receipt Status: Delivered Your item was delivered at 10 50 AM on December 21, 2009 in HARRISBURG, PA 17102. Detailed Results: • Delivered, December 21, 09,10:50 am, HARRISBURG, PA 17102 • Notice Left, December 18, 2009,12:18 pm, HARRISBURG, PA 17102 • Acceptance, December 17 2009, 4:19 pm, NEW CUMBERLAND, PA 17070 flikillfficadan Opttiow Track & Confirm by email Get current event information Or updates for your item sent to you or others by email. i Site Man Customer Service Fonns Gov't Services Careers Privacy Policy Terrns of Use Business Customer Gatewav Copyright© 2010 LISPS. All Rights Reserved. No FEAR Act EEO Data FOIA Ln r-, (Do mestic Only; No Insurance Coverage Pro-videdj F.r deliver informati i n it b it u7 y v o s our we s e at www.usps.come LT ? Postage $ j!5 4 ?•. ),'? Certified Fee / ^? ? ' R E d turn Receipt Fee t R i f t r iar r j +le 11 ( n or emen equ red) Restr' C3 (Endors ed Delivery Fee ement Required) ?'. ' Total Postage & Fees ru Q O \ Sent 5`treet 1 rY? pt. Nc?7-?---? - ??- ---- -C-C t'------------------ A? r - or PO Box No ? Clg; °° S -- " ! te, fff .-...'--" ------------- ?hu (1_I Sb AA ? I I ('a--! Exhibit "A" 1 of 1 1/29/2010 10:51 AM I U5 Postal Service 3/10/2010 1:45:30 PM PAGE 1/001 Fax Server UNI ED ST/1TES ANPOS7ZL SERVICE Date: 03/18/2010 Fax Transmission To: BARARA SULLIVAN Fax Number: 717-774-7050 Dear: BARBARA SULLIV The following is in response to your 03/18/2010 request for delivery information on your Certified Mail(TM) item number 7007 2680 0002 4649 5475. The delivery record shows that this item was delivered on 1 /21/2009 at 10:50 AM in HARRISBURG, PA 17102. The scanned image of the recipient infor ation is provided below. Signature of Recipient' Id I Address of Recipient: my T C., Thank you for selecting the ?ostal Service for your mailing needs. If you require additional assistance, pleas contact your local Post Office or postal representative. Sincerely United States Postal S Exhibit "A" JENNIFER L. MARKLEY : V. : CHRISTOPHER D. MARKLEY DIVORCE DECREE -~- /D ~ - ya •ryr AND NOW, 5U'+~`e ~~, ~O!'y , it is ordered and decreed that JENNIFER L. MARKLEY CHRISTOPHER D. MARKLEY bonds of matrimony. plaintiff, and 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. All matters have been resolved between the parties pursuant to the Marital Settlement Agreement dated June 14, 2010 and incorporated, but not merged, into this Decree. Attest: J. J Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 8639 AN~ ~.t t ~ va+n .