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Home My WebLink About10-1216 1ANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com ----------- - ------ - ---------- - ------ -- - TIMOTHY TURNBULL, Plaintiff vs. JESSICA TURNBULL, Defendant : y 2060 FES 22 P16 2: 4 9 CLJ,vd IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 1? - o - (? Civil Term : 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 ? 3 Via. 6 6 pt #, ie? c).3 `A? N JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com --------- ----------- ------- - - - -- - -- TIMOTHY TURNBULL, Plaintiff vs. JESSICA TURNBULL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 10- o-16 Civil Term : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Timothy Turnbull, a competent adult individual, who resides at 16 Sable Lane, Hedgesville, West Virginia, 25427. 2. Defendant is Jessica Turnbull, a competent adult individual, who resides at193 Chestnut Grove Road, Shippensburg, Cumberland County, Pennsylvania, 17013. 3. Plaintiff has been a bona fide resident of Pennsylvania during the past 6 months, and Defendant has been a bona fide resident of Pennsylvania for the past 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on December 20, 2003 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have one child together, namely, Adelalia Turnbull, bom May 28, 2004. A custody action has been filed under docket number 2009 - 8535 in Cumberland County. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I 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.C.S. §4904 relating to unsworn falsification to authorities. Dater Timothy Turnbull, Plaintiff Respectfully submitted, n Adams, Esquire D o-79465 7 est South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 2010 MAR _5 Pik Z' ~ ~ SANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esdadamsC~gmail.com CUM ~~ -,~ ~ - r. ---------------------------------------------- TIMOTHY TURNBULL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 10 - 1216 Civil Term JESSICA TURNBULL, :ACTION IN DIVORCE Defendant ACCEPTANCE OF SERVICE I, Douglas G. Miller, Esquire, represent Jessica Turnbull in the above- captioned matter; I hereby accepted service of the Notice to Defend and Complaint in Divorce on the date listed below, which was filed by Plaintiff's Attorney under the above-captioned number and I hereby affirm I was authorized to do so. Date: 3 S /o '~..~„~rl/. /1~D0,. Douglas G~ Miller`, Esquire I.D. No. 60 West Pomfret St. Carlisle, Pa. 17013 (717) 249-2353 ATTORNEY FOR DEFENDANT JUN 3 6ZU10 TIMOTHY TURNBULL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW JESSICA TURNBULL, NO. 2010-1216 Defendant IN CUSTODY COURT ORDER ~h AND NOW, this ~ day of ~ ~! ~Q„ , 2010, pursuant to the custody order entered at Docket No. 2009-8535, the father's petition for contempt filed to above docket is deemed to be dismissed. BY THE COURT, ~~. Judge M.L. Ebert, Jr. '~ J Adams Es uire cc: ~re q ./Douglas G. Miller, Esquire ~,~.,,~,l~L 7~t~~0 ~~ C a .,, _ ~ ~, ;~ ~ ~ ~ ~~ r,,, .; :~ . ~ ; , d`.,,X ~ ,iT7 ~~ ~_~ ~ ~ ~. ~- _ %,_. ` ~ .a-' •T (.~ .. ~ f ~~ ;" TIMOTHY TURNBULL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. • No. 10 - 1216 Civil Term JESSICA TURNBULL, • ACTION IN DIVORCE c=: Defendant : ;co o rte- c STATEMENT OF INTENTION TO PROCEED TO THE PROTHONOTARY: Plaintiff, Timothy Turnbull, intends to proceed with the above-captioned matter. Please remove this case from the termination list. Respectfully Submitted, I Date: a • (3 ne Adams, Esquire 7 W. South St. Carlisle, Pa. 17013. (717) 245-8508 ATTORNEY FOR PLAINTIFF OCT 22 rf 1 it .'_' i thEi∎LA! J U PENN S`r'LW , TIMOTHY TURNBULL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 10 - 1216 Civil Term JESSICA TURNBULL, : ACTION IN DIVORCE Defendant : CIVIL ACTION - LAW NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on cei2)- , 2009 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my 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. §4904 relating to unsworn falsification to authorities. Date: 1 o/J 2 o13 Timothy urnbull, Plaintiff • TIMOTHY TURNBULL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 10 - 1216 Civil Term JESSICA TURNBULL, : ACTION IN DIVORCE Defendant : CIVIL ACTION - LAW NOTICE TO PLEAD . �► c-) To: Jessica Turnbull, Defendant :� do Douglas Miller, Esquire ° :7Z 60 West Pomfret St. = Carlisle, Pa. 17013 -4 - -< You are hereby notified to file a written response to the attached Petition for ` Economic Relief within twenty (20) days from service hereof or a judgment may be entered against you. Date: !o ?, 3L3 . Afc..4..4 ' ,an- Adams, Esquire I.D. No. 79465 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF Timothy Turnbull • TIMOTHY TURNBULL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 10 - 1216 Civil Term JESSICA TURNBULL, : ACTION IN DIVORCE Defendant : CIVIL ACTION - LAW PLAINTIFF'S PETITION FOR ADDITIONAL ECONOMIC CLAIM AND NOW COMES, Plaintiff/Petitioner, Timothy Turnbull, by and through his Attorney, Jane Adams, Esquire, and respectfully represents the following: COUNT I - EQUITABLE DISTRIBUTION OF PROPERTY 1. Plaintiff and Defendant were married on December 20, 2003 and were separated on September 27, 2009. 2. Plaintiff/Respondent filed a Complaint in Divorce under the above-captioned docket number on February 22, 2010. 3. During the course of the parties' marriage, they acquired numerous items of property, both real and personal, and debts, which are held in joint names and in the individual names of each of the parties hereto. 4. Plaintiff and Defendant have been unable to agree as to an equitable division of said marital property and debt. 5. Plaintiff is seeking an equitable division of all marital property. 07.9e97/9e WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Plaintiff and Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. Respectfully submitted, Date: 23 ,/� . 1 �_ Lac/ �,3 Ja - dams, Esquire 13■ No. 79465 W. South Street arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF • i VERIFICATION I verify that the statements made in this PETITION are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: (0, P / s. /3 Timot urnbull, Plaintiff