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HomeMy WebLinkAbout09-8778IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Robert William Krohn Jr Plaintiff Pro Se, ?jv vs. NO. Melissa Sue Krohn Defendant Pro Se. 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 Cumberland County Courthouse, S. Hanover St., Carlisle, PA 17013. 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. 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 LAWYERS REFERRAL ERVI Telephone: Q? r Li ?i 7 a,3 lie The Court of Common Pleas of Cumberland County is required by law to comply with the with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to Notice to Defend and Claim Rights Page 1 of 2 disabled individuals having business before the Court, please contact the Court Administrator at (717) 240-6195. All arrangements must bemade at least 72 hours prior to any hearing or business before the Court. Notice to Defend and Claim Rights Page 2 of 2 4. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Robert William Krohn Jr 3016 Market Street Camp Hill, PA 17011 Plaintiff Pro Se, VS. Melissa Sue Krohn 1221 Ridge Road Richfield, PA 17086 Defendant Pro Se. NO. 7' ?7? cam; COMPLAINT IN DIVORCE Plaintiff, Robert William Krohn Jr, pro se, respectfully represents: 1. Plaintiff, Robert William Krohn Jr, currently resides at 3016 Market Street, Camp Hill, PA 17011. 2. Defendant, Melissa Sue Krohn, currently resides at 1221 Ridge Road, Richfield, PA 17086. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have been resident(s) 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 10/12/2002, in Mercersburg, PA. 5. The parties were separated on 09/15/2008. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 7. The parties have no minor or legally dependent children. 8. There have been no prior actions of divorce or for annulment between the parties. 9. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, fees and costs. Complaint in Divorce Page 1 of 2 .. 9- 10. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 11. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce pursuant to Section 3301(c) of the Divorce Code. Robert William lkrohn Jr, Plain iff Pro Se VERIFICATION Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Robert William ohn Jr, Plaintiff Pro Se Date: V!c -6,0 7 Complaint in Divorce Page 2 of 2 t C '' ': C 22 E'3 3: , ?3s331