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HomeMy WebLinkAbout09-8661SUSAN M. JORDAN, PLAINTIFF v. PAIGE D. JORDAN, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. (yq - 8(o(o( 0-4- vt I T r'm DIVORCE ACTION 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. A list of marriage counselors is available in the Office of the Prothonotary at (717) 240-6195, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 17103 (717) 240-6195 SUSAN M. JORDAN, PLAINTIFF V. PAIGE D. JORDAN, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09. 164/ LL? i? DIVORCE ACTION COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff, Susan M. Jordan, is an adult individual who currently resides at 101 November Drive, Apartment 4,Camp Hill, Pennsylvania 17011. 2. Defendant, Paige D. Jordan, is an adult individual who currently resides at 2908 Dalton Drive, Manchester, MD 21102. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on December 26, 1987, White Oak, WV. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, Susan M. Jordan, urges this Honorable Court to enter a Decree of Divorce. Respectfull f submitted, NEALON By: q PC James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, Susan M. Jordan, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: ('? 'Susan M. Jordan FILED C.=FjC • TAr7Y 2009 DEC f 6 ION' f: J "a J Y, $350 , oo Po ATTq Cy it 5603 R.T*ol, 3 644 ert xa!yl4 f SUSAN JORDAN, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-8661-Civil Term PAIGE D. JORDAN, DIVORCE ACTION DEFENDANT n!- -? AFFIDAVIT OF SERVICE :5 ?D tv I, James G. Nealon, III, Esquire, verify that on the 26th day of December 2009 I sRr ed tie Defendant with a true and correct copy of the Complaint for Divorce by one of the following methods: (CHECK ONE) ( X ) Service was made by United States Postal Service, first class mail, postage prepaid, certified, restricted delivery, return receipt requested to the Defendant, on the 26th day of December, 2009. The return receipt signed by the Defendant is attached hereto. ( ) The Defendant was personally served with a true and correct copy of the above pleading by hand-delivering the same to the Defendant. Personal service was made at following location and time: on the day of , 20 at I verify that the statements made in this affidavit are true and 00 ect. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.?. 904 relating to unsworn falsification to authorities. ..e--? I James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Dated: /// -? /'0 IV A ru L-i Ln M C3 C3 M h-' O E' L-i Ln c' 0r SUSAN JORDAN IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. PAIGE D. JORDAN No. NO. 2009-8661 DIVORCE DECREE AND NOW, r ~ 2.0 la , it is ordered and decreed that SUSAN JORDAN plaintiff, and PAIGE D. JORDAN ,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, R•9•ro ~ Q .9.10 ,~~; ~.