HomeMy WebLinkAbout09-8795KRISTY L. CLAYTOR,
Plaintiff
VS.
NATHANAEL P. CLAYTOR,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Oq - B745 Olvi ( enm
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 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, Cumberland County Courthouse, Carlisle,
Pennsylvania.
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.
Court Administrator
Cumberland County Courthouse
4th Floor, One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
KRISTY L. CLAYTOR, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO.
NATHANAEL P. CLAYTOR, CIVIL ACTION -LAW
Defendant IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE
1. Plaintiff is Kristy L. Claytor, an adult individual who resides at 206 N.
Enola Drive, Enola, Cumberland County, Pennsylvania 17025.
2. Defendant is Nathanael P. Claytor, an adult individual who resides at SCI
Camp Hill, PO Box 200, Camp Hill, Cumberland County, Pennsylvania 17001.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least
six months immediately previous to the filing of this complaint.
4. The plaintiff and defendant were married on January 7, 2006 at
Hummelstown, Pennsylvania.
5. A prior action for divorce was filed in the Court of Common Pleas, Potter
County, Pennsylvania, which divorce was discontinued December 7, 2009.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling and that
plaintiff has the right to request that the court require that the parties participate in
counseling.
8. Plaintiff requests the court to enter a decree of divorce
Timo O'Connell, Esquire
TURNE AND O'CONNELL
4701 North Front Street
Harrisburg, PA 17110
(717) 232-4551
Attorney for plaintiff
Verification
I verify that the statements made in the foregoing Complaint are true and correct.
I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
4411,1YI-) -J
Date: 09 Kristy L. a or
KRISTY L. CLAYTOR, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO.
NATHANAEL P. CLAYTOR, CIVIL ACTION -LAW
Defendant IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a
counteraffidavit within twenty days after this affidavit has been served on you or the
statements will be admitted.
Plaintiffs Affidavit Under
Section 3301(d) of the Divorce Code
1. The parties to this action have continued to live separate and apart for a
period of at least two years, since December 2006.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce
is granted.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
Date: ?a ` 9 Kristy L. ytor
FLEC-CAM
OF THE PRO 40MARY
M9 GEC "G AN 11: 46
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
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laintiff
Vs File No. j - 0 < 7 q
rr'' IN DIVORCE ;"- -3
efend
-, C? 3 ;
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
prior to the entry of a Final Decree in Divorce,
or - _7N after the entry of a Final Decree in Divorce dated 20
hereby elects to resume the p 'or surname of 1 o J
,and gives this
written notice av``owing hisl/ er intention pursuant to the provisions o 4 P. S. 704.
Date: -M j ) G -1")A-J\ I C f
gnature "?a
G
Sign of name being resume
COMMONWEALTH OF PE SYLVANIA )
COUNTY OF
On the ) 0 day of MarLAA , 20Q.t , before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose ther in contained.
In Witness Whereof, I hav hereunto set my hand hereunto set my hand and official
seal.
Prothonotary or--rotary Pu'olic v
144
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