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HomeMy WebLinkAbout04-3376PATRICK SULLIVAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : DOCKET NO. dr-1 - 33710 (2*10 `? JAMIE SULLIVAN, : 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. 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 at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PATRICK SULLIVAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :DOCKET NO. !'y - 3 37t. ?t u L (fowl JAMIE SULLIVAN, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE Plaintiff, Patrick Sullivan, is an adult individual who currently resides at 4 Johns Drive, Enola, Cumberland County, Pennsylvania 17025. His date of birth is March 27, 1977, and his social security number is 166-58-9236. 2. Defendant, Jamie Sullivan, is an adult individual who currently resides at 230 Sam Snead Circle, Etters, York County, Pennsylvania 17319. Her date of birth is April 4, 1983, and her social security number is 169-70-4655. 3. Plaintiff and Defendant have been bonafide residents in the Commonwealth of Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint in Divorce. 4. The Plaintiff and Defendant were married on March 21, 2003, in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no other prior actions of divorce or annulment filed by either of the parties hereto. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the Court enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; and b. Granting such further relief as the Court may determine equitable and just. Respectfully submitted, Heather M. Faust Attorney ID #77947 Killian & Gephart 218 Pine Street Harrisburg, PA 17101 (717) 232-1851 Dated: July 8, 2004 Attorneys for Plaintiff 2 VERIFICATION I hereby verify that the statements of fact made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa.C.S.A. §4904, relating to unworn falsification to authorities. July 8, 2004 (U" Patrick Sullivan G n? Curtis R. Long Prothonotary office of the protbonotarp Cumberlanb QCountp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor nq - 33 N2 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 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, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573