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Home My WebLink About10-1650" r ANDREW J. BENDER, ESQUIRE PA Supreme Court ID #: 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax FILED- --)Fr'%nE )F THE Fin;PH(-)N10TARY 2010 MAR -9 AN If: 39 CUAf - ,i `'ly IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN J. EISEMANN, CIVIL ACTION - LAW Plaintiff NO.: lb -It. S6 V. PAUL C. YESAVAGE, 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. 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 TELEPHO THE OFFICE SET FORTH ON THE FOLLOWING PAGE. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER p-gazo ?,(- & 94? 1171 ?.? aae?vy S t r IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 ANDREW J. BENDER, ESQUIRE PA Supreme Court ID #: 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN J. EISEMANN, Plaintiff V. CIVIL ACTION - LAW NO.. 10- N Sd PAUL C. YESAVAGE, Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Kathleen J. Eisemann, an adult individual who currently resides at 323 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Paul C. Yesavage, an adult individual whose last known address is P.O. Box 725, Foxworth, Mississippi 39483. 3. Plaintiff and Defendant were lawfully married on February 18, 2009 in Carlisle, Cumberland County, Pennsylvania. 4. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of the instant Divorce Complaint. 5. Plaintiff and Defendant have been separated since January 28, 2010, when the Defendant vacated the marital residence. 6. The marriage is irretrievably broken. 7. There have been no prior actions for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces. 9. The Plaintiff has been advised of the availability of marriage counseling and that she has the right to request the Court to require the parties to participate in marriage counseling. COUNT I - REQUEST FOR NO-FAULT DIVORCE PURSUANT TO & 3301(c) OF THE DIVORCE CODE 10. Paragraphs 1 through 9 are incorporated herein by reference as though fully set forth herein. 11. The marriage is irretrievably broken. 12. After ninety (90) days have elapsed from the date of the filing of this Divorce Complaint, the Plaintiff may file with the Court an affidavit consenting to the entry of a divorce decree. The Plaintiff believes and, therefore, avers, that the Defendant may also file such an affidavit. WHEREFORE, if Plaintiff and Defendant each file affidavits consenting to a divorce after ninety (90) days have elapsed from the filing of the Divorce Complaint, the Plaintiff, Kathleen J. Eisemann, respectfully requests this Honorable Court enter a Divorce Decree, pursuant to § 3301(c) of the Divorce Code. 2 COUNT II - REQUEST FOR NO-FAULT DIVORCE PURSUANT TO 6 3301(d) OF THE DIVORCE CODE 13. Paragraphs 1 through 12 are incorporated herein by reference as though fully set forth herein. 14. The marriage is irretrievably broken. 15. After a period of two (2) years has elapsed from the date of the filing of this Divorce Complaint, the Plaintiff may file with the Court an affidavit setting forth that she has lived separate and apart from the Defendant for a period of two (2) years. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed an affidavit setting forth that Plaintiff and Defendant have lived separate and apart for two (2) years, the Plaintiff, Kathleen J. Eisemann, respectfully requests this Honorable Court enter a Divorce Decree pursuant to § 3301(d) of the Divorce Code. Respectfully submitted, ANDREW J. BENDER, ESQUIRE Attorney for Plaintiff PA Supreme Court ID # 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax 'J VERIFICATION I, KATHLEEN J. EISEMANN, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge and belief. 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: SZS` KATHLEE J. EISEMANN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHLEEN J. EISEMANN, CIVIL ACTION - LAW Plaintiff NO.. V. PAUL C. YESAVAGE, Defendant IN DIVORCE CERTIFICATE OF SERVICE The undersigned does hereby certify that a true and correct copy of the foregoing Divorce Complaint was served on the following, in accordance with Pa.R.C.P. 1930.4(c), by forwarding same via certified mail, restricted delivery, return receipt requested, and first-class mail postage prepaid to the Defendant's last known address as indicated below: Paul C. Yesavage P.O. Box 725 Foxworth, MS 39483 DATE: 0310111o ANDREW J. BENDER, ESQUIRE Attorney for Plaintiff PA Supreme Court ID # 205763 Allied Attorneys of Central Pennsylvania, L.L.C. 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 (717) 249-4514 Fax David D. Buell e Renee X Simpson Prothonotary ; M 15t Deputy Prothonota �irkS. Sofionage, ES Q. V •-•‘\ - ° Sys Irene E. .911orrow u_a Solicitor „SO 2"d Deputy Prothonotary Office of the Prothonotary Cum6erCand County, cPennsyCvania -l p ga 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., ,(717)240-6573