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HomeMy WebLinkAbout10-2993 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, - `? 14 PENNSYLVANIA r- CIVIL ACTION-LAW ui Tammy Lyn Moore' w Plaintiff Pro Se, VS. NO. lo Givil Iexm Robert James Moore Defendant Pro Se. 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 Cumberland County Courthouse, S. Hanover St., 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. 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 LAWYERS REFERRAL SERVICE 32- Sow Q ?? rcr' ?? Telephone: °1\'1 ' 2?-?q' 3\ 4 35a .oo Pb P):F M44 Ot 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 Notice to Defend and Claim Rights Page 1 of 2 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Tammy Lyn Moore 267 High Mountain Road Shippensburg, PA 17257 Plaintiff Pro Se, vs. NO. ?a v o?C193 6'`''" Robert James Moore 267 High Mountain Rd Shippensburg, PA 17257 Defendant Pro Se. COMPLAINT IN DIVORCE Plaintiff, Tammy Lyn Moore, pro se, respectfully represents: 1. Plaintiff, Tammy Lyn Moore, currently resides at 267 High Mountain Road, Shippensburg, PA 17257. 2. Defendant, Robert James Moore, currently resides at 267 High Mountain Rd, Shippensburg, PA 17257. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have been resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on 04/02/1991, in Montour Falls, NY. 5. The parties were separated on 05/01/2007. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 7. The parties have no minor or legally dependent children. 8. There have been no prior actions of divorce or for annulment between the parties. 9. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, fees and costs. Complaint in Divorce Page 1 of 2 A' 10. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 11. Plaintiff waives the right to request that the court require the parties to participate in counseling. 12. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce pursuant to Section 3301(c) of the Divorce Code. t) Tammy Lyn Moo intiff R Se VERIFICATION Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Tammy L oo Plain ' Pro Se _ _t) Date: ':?- - TS " \ \D Complaint in Divorce Page 2 of 2 I O --t - lp rl i o? J Z w 0 0) Z a) 6 ro U ? J C r O L v, tz ?- i-+ I V co ? Q O 4-0 J ? V O z V N E m F- :3 a? O> m N E a m m E m ` x O 9 O U O L O m U [L h ? N A 0 12 W iL Z E 0 0 14 Pi N z O J-) to El Cd (1) E m m c E ? a? c or m N a T) a) 6 - CL o E C ? m - ?O c U U T) E L o O Z U m ? at U c D or t6 m ? 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