HomeMy WebLinkAbout04-3870JOHN McANDREWS,
Plaintiff
VS.
ROBERTA McANDREWS,
Defendant
· IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION-LAW
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 Qffice of the Prothonotary, Cumberland County Courthouse, One
Courthouse Square, Carlisle, PA.
DF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAVVYER'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
QFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD
CARLISLE, PA 17013
(717) 249-3166 OR (800)990-9108
JOHN McANDREWS,
Plaintiff
VS.
ROBERTA McANDREWS,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO:
: CIVIL ACTION-LAW
NOTICE OF AVAILABILITY OF
COUNSELING TO THE WITHIN NAMED DEFENDANT
You have been named as a Defendant in a divome proceeding filed in the Court
of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with §3302 (c) or (d) of the Divome Code, you may request that the court
require you and your spouse to attend mardage counseling pdor to a divorce decree
being handed down by the Court. A list of professional marriage counselors is available
at the Cumberland County Courthouse, Cumberland County, Pennsylvania. You are
advised that this list is kept as a convenience to you, and you are not bound to choose a
counselor from the list. All necessary arrangements and the cost of counseling
sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty (20) days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
JOHN McANDREWS,
Plaintiff
VS.
ROBERTA McANDREWS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
DIVORCE COMPLAINT
1. Plaintiff is John McAndrews, an adult individual who currently resides at
P.O. Box 312, Middletown, Dauphin County, Pennsylvania.
2. Defendant is Roberta McAndrews, an adult individual who currently
resides at 201 Houston Drive, Grantville, Dauphin County, Pennsylvania.
3. The Plaintiff has been a bona fide resident(s) 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 February 20, 2003, in
Wellsboro, Tioga County, Pennsylvania.
There have been no prior actions for divorce or for annulment between the
parties.
6.
The Plaintiff in this action is not a member of the Armed fomes.
7. Plaintiff and Defendant are both citizens of the United States.
8. Plaintiff has been advised of the availability of marriage counseling and
that he may have the right to request the court to require the parties to participate in
such counseling. Being so advised, Plaintiff does not request that the court require the
parties to participate in counseling prior to the divorce decree being handed down by
the court.
9. The mardage is irretrievably broken.
WHEREFORE, the Plaintiff respectfully requests this Honorable Court to enter a Decree
of Divorce.
Date: August 6, 2004
Respectfully submitted,
Abom& Kutulakis, L,L.P,
Kara W. Haggerty,..LE~s~l'~ire / ~'
Attorney I.D. No, ~,o'-J'~- ( J
36 South Hanover Street '"
Carlisle, PA 17013
(717) 249~0900
Attorney for Plaintiff
JOHN McANDREWS,
Plaintiff
VS.
ROBERTA McANDREWS,
Defendant
· IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO:
: CIVIL ACTION-LAW
VERIFICATION
I vedfy that the statements made in the foregoing Complaint in Divome 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.
Date
ews
JOHN McANDREWS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
VS. :
: NO:
ROBERTA McANDREWS,
Defendant
CIVIL ACTION-LAW
AFFIDAVIT OF SERVICE
AND NOW, this 6th day of August, 2004, I, Kara W. Haggenty, Esquire, hereby
certify that I did serve a true and correct copy of the foregoing Divorce Complaint upon
the Defendant, by U.S. Postal Service, Certified Mail, Return Receipt Requested,
addressed as follows:
Roberta McAndrews
201 Houston Drive
Grantville, PA 17028
36 South Hanover Street
Carlisle, PA 17013
Attorney for Plaintiff
JOHN McANDREWS,
Plaintiff
VS.
ROBERTA McANDREWS,
Defendant
IN THE cOURT OF COMMON PLEAS
: CUMBERLAND couNTY, PENNSYLVANIA
: NO: 04-3870
: CIVIL AC I ION-LA¥~
AFFIDAVIT OF SERVI_CE
I, David K. Rudy, hereby certify that I did personally serve a true and
correct copy of the Divorce Complaint in the above-captioned case upon the
Defendant, Roberta McAndrews, at ~~ ~t0~ ~o~,qzqttt. z0_ on
the_ [._'~ayof ~~°r~.,~2004 at fxzL~°'~-M'
Respectfully submitted,
New Cumberland, PA 17070
(717) 932-8862
JOHN McANDREWS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO: 04-3870
ROBERTA McANDREWS,
Defendant
CIVIL ACTION-LAW
TO THE PROTHONOTARY:
PRAECIPE TO WITHDRAW AND DISCONTINUE
Please mark the above-captioned divorce withdrawn.
Respectfully submitted,
Abom & Kutu/akis, L.L.P.
Date: January 14, 2005
/4wJi) .
Kara W. Haggerty,
Attorney LD. No.
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Plaintiff
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