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HomeMy WebLinkAbout10-2394April M. Murray, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Denny E. Murray, Id -,; 3 ,9Y Defendant :NO. 10- CIVIL TERM _; NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set ford in the following pages, you must take prompt action. You are warned that if you fail to doh, thccaseil 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 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, Cumberland County Courthouse, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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, Pennsylvania 17013 (717) 249-3166 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. April M. Murray, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Denny E. Murray, 16- J-3 9 Defendant :NO. 10- CIVIL TERM DIVORCE COMPLAINT The plaintiff, April M. Murray, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. M3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is April M. Murray, who currently resides at 115 B South Hanover Street 2. Carlisle Cumberland County, PA 17013, since December 2009. 3. Defendant is Denny E. Murray, who currently resides at 133 South East Street, Carlisle, Cumberland County, PA 17013, since January 2010. 4. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on June 26, 2008 in Newville, Cumberland County, Pennsylvania. 6. Plaintiff and Defendant have lived separate and apart since November 28, 2008. 7. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 9. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. 4ifiCe yn AN do ed Le g al Intern rn MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. .01 Date 9 -l -1 o Plaintiff Ap 1 M. Murray April M. Murray, : IN THE COURT OF COMMON PLEAS OF ' Plaintiff : CUMBERLAND COUNTY, PENNSE,VANIX--l- o x,. _--+ V. : CIVIL ACTION - LAW -T' IN CUSTODY =z'- -rim Denny E. Murray, Defendant : NO. 10-.1391 CIVIL TERM a. `x' PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow April M. Murray, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 12 2-0)0 Respectfully submitted, 4?"A quel lvarado rti ge ie Legal Intern MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 IN THE COURT OF COMMON PLEAS OF April M. Murray :CUMBERLAND COUNTY, PENNSYLVANIA V. Denny E. Murray 10-2394 NO. DIVORCE DECREE AND NOW, l v2 ~~' , it is ordered and decreed that April M. Murray plaintiff, and Denny E. Murray ,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, `~~. ~;~; ~