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HomeMy WebLinkAbout10-2510F:\DOCS\FL\DIV\Strawn.Gregory - 3301(c) complaint & verification.wpd ELIZABETH B. STONE, ESQ 1) F I?-Q)P ATTORNEY ID NO. 60251 Tf T"JbrAW 414 BRIDGE STREET ?O1?APR !6 Alp: NEW CUMBERLAND PA 17070 3 (717) 774-7435 ATTORNEY FOR PLAINTIFF ?tL4,t.1 i i C^? ran„ GREGORY H. STRAWN, Plaintiff V. TERESA M. STRAWN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. /Z/,'- CIVIL ACTION - LAW 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 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 Courthouse, Carlisle, PA 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 TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 2,j r Cumberland County Bar Association A ?Lt``?3?a- D? i J 32 South Bedford Street q Carlisle, PA 17013 ?,?# ?G Telephone: (717) 249-3166 'ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF GREGORY H. STRAWN, Plaintiff V. TERESA M. STRAWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is GREGORY H. STRAWN, an adult individual, who currently resides at 28 Cedar Cliff Drive, Camp Hill, Pennsylvania 17011. 2. The Defendant in this action is TERESA M. STRAWN, an adult individual, who currently resides at 1740 Rock Cliff Drive, Martinsburg, West Virginia 25401. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on September 6, 2003, in Adams County, 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 Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. i 7. The Plaintiff avers that no children have been born of this .,,marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of divorce. Date: , ,p/ STONE LaFAVER & 2IEKLETSKI Eli th Shane, Esquire e41 r me u D # 60251 Bridge reet, P.O. Box E New Cumbe and, PA 17070 Telephon 717-774-7435 5 Attorneys for Plaintiff v V E R I F I C A T I O N GREGORY H. STRAWN states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Y 9. S Date fi\dic\WAYPJE,LISA-ordert;cincorpcrate GREGORY H. STRAWN, Plaintiff v. TERESA M. STRAWN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-2510 CIVIL ACTION - LAW IN DIVORCE O R D E R AND NOW, this day of 2010, the Agreement between the parties dated April 3, 2010, and attached hereto is hereby incorporated into the Decree in Divorce. BY THE ;C-O?TRT J. 1? -J'?ie?sA S?rr?usk Ct)psfs Kt& Ied Rla3/io Y' -n t IN THE COURT OF COMMON PLEAS OF GREGORY H. STRAWN CUMBERLAND COUNTY, PENNSYLVANIA , V. TERESA M. STRAWN, NO 10-2510 DIVORCE DECREE AND NOW, it is ordered and decreed that GREGORY H. STRAWN, plaintiff, and TERESA M. STRAWN, , 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.") The Property Settlement Agreement dated April 3, 2010, is hereby incorporated, but not merged into the Decree in Divorce. By the-C&Url, Attest: J. : Prothonotary 6&)2y 710;tw 1? d, 1-1 -