HomeMy WebLinkAbout02-0079DONNA A. EVERIDGE,
Plaintiff
Vo
DAVID E. EVERIDGE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2002- q~ CIVIL TERM
:
: 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 divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the
Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania.
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 Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
DONNA A. EVERIDGE,
Plaintiff
DAVID E. EVERIDGE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2002- ?~ CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF
THE DIVORCE CODE
The Plaintiff, Donna A. Everidge, through her attorney, Thomas S. Diehl, makes the
following Complaint in Divorce, and, in support thereof, avers as follows:
1. The Plaintiff, Donna A. Everidge, is an adult individual who currently resides at
1364 Main Street, Box 4B, Valley View, Schuylkill County, Pennsylvania 17983.
2. The Defendant, David E. Everidge, is an adult individual who currently resides at
332 Sears Road, Richford, Tioga County, New York, 13835.
3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania
for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on October 1, 1988 in Forsyth,
Monroe County, Georgia.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Defendant is not a member of the Armed Forces of the United States of
America or its Allies.
7. The Plaintiff has been advised of the availability of counseling and the right to
request that the Court require the parties to participate in counseling. Knowing this, Plaintiff
does not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
WHEREFORE, the Plaintiff, Donna A. Everidge, respectfully requests your Honorable
Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code.
Date: January 7, 2002
Respectfully submitted,
Attorney for the Plaintiff
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
(717) 240-0893 - FAX
VERIFICATION
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
unswom falsification to authorities.
DONNA A. EVERIDGE, Plaintiff
DONNA A. EVERIDGE,
Plaintiff
DAVID E. EVERIDGE,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2002-79 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this 14th day of January 2002, comes Thomas S. Diehl, Esquire, Attorney for
the Plaintiff, Donna A. Everidge, and states that he had cause to be mailed a certified copy of a
Complaint in Divorce to the Defendant, David E. Everidge, by certified, restricted delivery,
return-receipt requested. A copy of said receipt is attached hereto indicating service was made
on January 10, 2002.
Respectfully submitted,
Thomas S. Diehl
Attorney for the Plaintiff
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
(717) 240-0893 - FAX
Return Receipt Fe~
· Pdr~
1. Article Addressed to:
D. i$ dGlivefy addree~ dilfGnlnt~f~o~n i
DAVID E. EVERIDGE
332 SEARS ROAD
RICKFOI~D, NY f3835
3. Service Type
i"/ Registered
. [] Insured Mail
2. ,NlJcle Number ~: .*
IPS Form 3811, March 2001
. •Agar
OYe~
[] No
7000 ~6~P 0001 879.6 3,7.53