HomeMy WebLinkAbout10-3926
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~1~ THE F~"~^r~. ~~•,~~,ryTARy'
2010 JU6d 15 Ph 4~ 2 I
AMON DARR, IN THE COURT OF COMMON PLEAS
Plaintiff CUM~~~:;~._?•~ ~~~i~C~iTY CUMBERLAND COUNTY, PA
~cU~VSYC.V~iA
v, NO. ~G' ~d~ CIVIL TERM
CHRISTINA DARR, CIVIL ACTION -LAW
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, Cumbexland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS'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.
CUMBERLAND CO UNTY BAR ASSOCIATION
32 SOUTH BEDFORD
CARLISLE, PA 17013
(717) 249-3166 OR (800)990-9108
~~t ~p ~ ~ ~13~
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AMON DARK,
Plaintiff
v.
CHRISTINA DARR,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. CIVIL TERM
CIVIL ACTION -LAW
IN DIVORCE
COMPLAINT
1. Plaintiff is AMON DARK, who currently resides at 756 Hamilton Street, Carlisle,
Pennsylvania, but has a mailing address of 858 Alexander Spring Road, Carlisle, Cumberland
County, Pennsylvania 17015.
2. Defendant is CHRISTINA DARR, who currently resides at 760 Hamilton Street,
Carlisle, Pennsylvania 17013.
3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth
for at least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 24, 2003 at Cumberland County,
Pennsylvania.
COUNT I -DIVORCE
5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by
reference as though set forth in full.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301 (c) and
3301(d), in that:
a. The marriage is irretrievably broken.
b. Plaintiff and Defendant have lived separate and apart since May 1, 2010 and
continue to do so.
8. 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 such counseling.
9. The Plaintiff in this action is not a member of the Armed forces.
i~HEREFORE, the Plaintiff requests the Court to enter a decree of Divorce.
Respectfully submitted,
DaTE 0 D
Aaolrr & SUTULASIS, L.L.P.
Kara W. Haggerty, E;
Supreme Court ID N
2 West High Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Plainti~'
7
~RTFi_rATION
I, AMON DARK, verify that the statements made in this Divorce and Custody Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn
falsification to authorities.
Date ~ ` ` ` ~ ~ y
AMON DARR
OM ~' (~F 71-iF PF~~.,-:.,,~iTARY
LITLILAKIS 2010 Jt1~ 24 PM 3~ t 3
Kara W. Haggerty, Esquire
Attorney I.D. #: 86914
2 West High Street C~~-~.~.r14,,.:~`ry ;~'.,h,~N~Y
Carlisle, PA 17013 ~.'~~k~~V~~~,!~~?ir4,
(717) 249-0900
AMON DARR, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PA
v NO. 10-3926 CIVIL TERM
CHRISTINA DARK, CIVIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of
the Complaint under Sections 3301 (c) and (d) of the Divorce Code, upon the Defendant, by
depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery,
postage prepaid, on Christina Darr, of Carlisle, Pennsylvania, addressed as follows:
Chrstina Darr
760 Hamilton Street
Carlisle, PA 17013
Return card acknowledging receipt on June 18, 2010 is attached as Exhibit "A".
Respectfully submitted,
DATE ~~ ~ ~' `
ABOM & KUTULAKIS, L.L.P.
Kara W. Haggerty, Esquire
Attorney ID No. 86914
2 West High Street
Carlisle, PA 17013
(717) 249-0900
Attorney for the Plaintiff
^"C-.omplAfe itgfs+s~1, 2, and•3. Also complete
item 4 if Restricted Delivery is desired.
^ Print your name and address on the reverse
so that we can return the card to you.
^ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressedto:
~up1~w.
Cc~.Q,~Q.t,~c~.. ~7~~3
^ Agent
(/~~ ^ Addressee
~eceived by (Printe¢Q(ame) C. date of Delivery
111111 r-~TLIVI /~ IL 1A,1, Yv ~"'~$-t~
D. Is delivery address different from item 1? ^ Yes
If YES, enter delivery address below: ^ No
~~~ ~
O i
1
3. Service Type
~6ertNied Mail ^ Expres
^ Registered ^ Return
^ Insured Mail ^ C.O.D.
4. Restricted Delivery? (Extra Fee
r-I
forME
Z
2. Article Number 708 183 ~pp3 5942 5562
(bansAarfrom se-vloe label!
PS Form 38i 1, February 2004 Domestic Return Receipt
'~'
102585-02-M-t 540
EXHIBIT "A"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Amon Darr
V.
Christina Darr
NO. 10-3926
DIVORCE DECREE
AND NOW, u?¢ Ol , it is ordered and decreed that
Amon Darr plaintiff, and
Christina Darr
, 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,
Attest: J.
?' ?j. 3ve Prothonotary
$ 10 / Cer P? Dove r
1o?i? e cc ?e `E'od