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HomeMy WebLinkAbout10-1455r.• W, Ashley A. Russell N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10- f y S? CIVIL TERM Daniel R. Russell Defendant IN DIVORCE 4 ,a 4 R .PPI n zo 41 c? t NOTICE TO DEFEND AND CLAIM RIGHTS O-P ort YOU HAVE BEEN SUED IN COURT. If you wish to defend against the clalgs s 9? 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 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, 1 Courthouse Square, 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Ashley A. Russell IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA NO. 10- j ySs CIVIL TERM V. Daniel R. Russell Defendant IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is who currently resides at \x,45 F- ern S? C^c\?5\e Q? \^1()?3 Cumberland County, Pennsylvania. 2. Defendant is Cc.r.? who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on k ego 1???'" 00-1 at 5. The marriage is irretrievably broken, and the parties separated on 'veb pa aooa 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. aI ID Date Plaintiff, Pr Se I, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. 011 a[to Date: AJW ?AAW VL- Plaintiff, Pr e Assisted by: Jerry Brown, Esq. 4601 S. Clearview Dr. Camp Hill, PA 17011 (717) 737-9174 4 Ashley A. Russell Plaintiff V. Daniel R. Russell IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10- 15,5 CIVIL. TERM Defendant IN DIVORCE w -0 F4 C' j. PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: .0 n Kindly allow, Ashley A. Russell, Plaintiff, to proceed in forma au ens. I, Jerry Brown, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jerry rown, Esquire Atto ey for Plaintiff 460 Clearview Dr. C Hill, PA 17011 (71 737-9174 _To 4;3fr ASHLEY A. RUSSEL V. DANIEL R. RUSSEL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 1455 DIVORCE DECREE AND NOW, ? C?JIG? ?0 /8 , it is ordered and decreed that ASHLEY A. RUSSEL plaintiff, and DANIEL R. RUSSEL , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, Attest: Prothonotary la?a lio - &t"t Oopy /haLlwl 4o aMq Brown IMPCs) No*is mailer lo be f t