The URL can be used to link to this page

Home My WebLink About04-2598 JAMES B. BUSBY, SR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 2004- .J S 11 CIVIL TEACHNELlAR T. BUSBY, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW comes James B. Busby, Sr., plaintiff herein, by and through his attorney, Jacqueline M. Verney, Esquire, and represents the following: 1. Plaintiff is James B. Busby, Sr., an adult individual, currently residing at 707 Hanover Manor, Apartment D-1 01, Carlisle, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Teachneliar T. Busby, an adult individual, currently residing at 617 Ligett Ro Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth of Pennsylvania a have been so for at least six months immediately previous to the filing of this complair 4. Plaintiff and Defendant were married on March 26, 2002 in Carlisle, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff has been advised ofthe availability of marriage counseling and the PI have the right to request that the Court require the parties to participate in counsel Having been so advised Plaintiff does not desire the Court to order counseling. 7. This marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, & - 9 -0 r ~ - I. ^ JLL tit" d~erneY,ES~ Supreme Ct.IO. 23167 44 South Hanover Street Carlisle, P A 17013 (717) 243-9190 Attorney for Plaintiff VERIFICATION I verifY that the statements made in the foregoing divorce complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. cPv )0"16< ([)'1. Date /V) 4~ B~ntiff ~~ ~" ~, -.\ C\ I;:; --- \J ~ ", c:, ~ "- ..:;) <> c.... C>i " \.~' ,.---' C:;, ,:-:; .1~-. ~~ . - ~ -T-. ~ D' JAMES B. BUSBY, SR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO, 2004- :J. S9? CIVIL TERM TEACHNELlAR T, BUSBY, Defendant 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 will proceed without you and a decree in divorce or annulment may 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 or 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 the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 Street Carlisle, Pennsylvania 17013 (717) 249-3166 JAMES B. BUSBY, SR" Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2004- '.1. 'S 'Ii CIVIL TERM TEACHNELlAR T. BUSBY, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service ofthe Complaint in Divorce in the above captioned matter pursuant to Pennsylvania Rule of Civil Procedure, Rule 1930.4(d). 1 certify that I am defendant or am authorized to accept service on behalf of defendant Date: :lul1t (f1 r ;). (j)L( -g~ efendant or Authorized agent tol'? DC(eN 6Zd ('c;,rl(s{p/i1I7O!!:::> Address C) ,:; C.Y~ , C. r.::_-: :;i '- '" = = .r- '- c: o -n :o:J -'Tl rnF :xES 1:'-'ll ~~~i~ ~2o (5,n ., :';:) -< N N ~~'''' -,,, c::5 U1 -=- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES B. BUSBY, SR., Plaintiff v. CIVIL ACT][ON - LAW No. 2004-2598 TEACHNELIAR T. BUSBY, Defendant PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Defendant, Teachneliar T. Busy, in the above- captioned matter. Respectfully submitted, HANFT & KNIGHT, P.C. Dated: June 25,2004 &:H'"~ ""oi" Attorney J.D. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys fi)r Defendant , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES B. BUSBY, SR., Plaintiff v. CIVIL ACTION - LAW No. 2004-2598 TEACHNELIAR T. BUSBY, Defendant CERTIFICATE OF SERVICE AND NOW, this 25th day of June, 2004, I, Michael 1. Hanft, Esquire, hereby certify that I have this day served the following person with a copy ofthe foregoing Praecipe to Enter Appearance by first class, United States Mail, postage pre-paid, addressed as follows: Jacqueline M. Verney, Esquire: 44 South Hanover Street Carlisle, Pennsylvania 17013 Attorney for Plaintiff HANFT & KNIGHT, P.C. ~ Attorney LD. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys ~Dr Defendant F:\User Folder\Finn Docs\Gendocs2004\3624-1praecipe,ellter,wpd c~ C) , =2 ", c-=-., ~~ c_ ~ ('J -n =;:J ((1 ;:u -rj fT1 -"JO (.~: , -' c..\- ~::.:j .-> <~ ~~~ ~5rn .---i ::] .-< ~- '" CO :,s N o JAMES B, BUSBY, SR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO. 2004-2598 CIVIL TERM TEACHNELIAR T, BUSBY, Defendant : IN DIVORCE PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONTARY: The undersigned, Jacqueline M. Verney, Esquire, counsel for Plaintiff, hereby withdraws the complaint in the above captioned matter. Respectfully submitted, 1(,0 Jacq line M. Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff cc: Jacqueline M. Verney, Esquire Teachneliar T. Busby, pro se ...0::, f-",) c::) ..:,;-; o -0 <-1 ~-i- ;-:fl -~~ (~':~ ~ -CI o