HomeMy WebLinkAbout10-1236Alicia K. Russell, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
V. No. 2010- 1,73&
Kenny A. Russell, C:D
Defendant IN DIVORCE rn -r
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NOTICE
You have been sued in court. If you wish to defend against the claims set foii in !fie
following pages, you must take prompt action. You are warned that if you fail to do=do, tha casiImay
proceed without you and a decree of divorce or annulment may be entered against you byViie co-76d.
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 the Cumberland County Court House, High and Hanover Streets, Carlisle.
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
Alicia K. Russell, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
vi. No. 2010- 1 3( < iv,
Kenny A. Russell,
Defendant IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Alicia K. Russell, who currently resides at 3523 Rolo Court, Cumberland
County, Mechanicsburg, Pennsylvania 17050.
2. Defendant is Kenny A. Russel, who is believed to be currently residing at Keystone
Correctional Services, Inc. 234, 7201 Allentown Boulevard, Harrisburg, Pennsylvania 17112.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on, September 13, 2001 in Hummelstown,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in
this or any other jurisdiction.
6. The marriage is irretrievably broken, and the parties were separated on July 10, 2007.
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 in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in
Divorce and such other Orders as may be just and appropriate.
ByZY-? Alicia K. Russell, pro se
VERIFICATION
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 unworn
falsification to authorities.
Date:
Alicia K. Russell, Plaintiff
Assisted by Vincent M. Monfredo, Esquire
ROMINGER & ASSOCIATES
155 South Hanover Street
Carlisle, PA 17013
Alicia K. Russell IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V.
Kenny A. Russell
Defendant
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NO./10 - /-;3(0 CIVIL TERM
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,
IN DIVORCE rv "r
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Alicia K. Russell Plaintiff, to proceed in forma au eris.
I, Vincent M. Monfredo, attorney for the party proceeding in forma ap uperis,
certify that I believe the party is unable to pay the costs and that I am providing free legal
services to the party.
Vincent M. Monfredo, Esquire
Attorney for Plaintiff
Rominger Law Office
155 S. Hanover Street
Carlisle, PA 17013
(717) 241-6070
of CUB
David D. Buell e Q Renee X Simpson
Prothonotary 1s` Deputy(Prothonota
\ td.•7(irkS. Sohonage, ESQ ,f.`�, �.y Irene E. Morrow
Solicitor 1750 2ne Deputy Prothonotary
Office of the Prothonotary
Cum6erCand County, Pennsylvania
/0 -"'/ to CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
PA R.C.P.230.2.
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • 'Fa.0(717)240-6573