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HomeMy WebLinkAbout10-3352{~ ~FIL~ ~-''~r~E t.E.~.RY ZU10 ~~~' p 9 P~ f2~ U2 iANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esdadams~gmail.com JUDY M. MUSSELMAN, Plaintiff vs. DOUGLAS J. MUSSELMAN, Defendant n - IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN{A No. /0 _ ~335~ ~ Civil Term ACTION IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defiend 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 ;35~ •~ ~ ~ lv~~ ~ ~ ~~~ ,~ /L'l~Zcy.i~ 3 9 r. s"a ~~ ~,~s~~i ~ ~"a 3 ~S iANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esyadams@gmail.com JUDY M. MUSSELMAN, Plaintiff vs. DOUGLAS J. MUSSELMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE COUNT I -DIVORCE 1. Plaintiff is Judy M. Musselman, a competent adult individual, who resides at 1151 Pine Road, Carlisle, Cumberland County, Pennsylvania, 17015. 2. Defendant is Douglas J. Musselman, a competent adult individual, who resides at 1151 Pine Road, Carlisle, Cumberland County. Pennsvlvania_ 17015 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on March 21, 2005, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT II -EQUITABLE DISTRIBUTION OF PROPERTY 11. Paragraphs 1 - 14 are herein incorporated by reference. 12. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. oae s~i~~(o J - dy . Musselman, Plaintiff Respectfully submitted, la a Adams, Esquire . No. 79465 West South St. 'Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF OF cU 41 -1 N..��i David D. Buell h „ B. Renee X Simpson Prothonotary . ., y 1st Deputy Prothonotary 1 9 . ` o �irkS. Sohonage, ESQ, Irene E. W orrow Solicitor 1750 2"e Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania /01-33S-02. 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 • rFax(717)240-6573