HomeMy WebLinkAbout02-0222TERRY KEITH JONES, :
Plaintiff :
:
V. :
:
BERNADETTE JONES, :
Defendant :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~-' ~[ ~
IN DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 judgement 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, 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
TERRY KEITH JONES,
Plaintiff
V.
BERNADETTE JONES,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,. PENNSYLVANIA
.
: NO. d'~oq:~
:
: IN DIVORCE
.'
location.
2.
COMPLAINT
The Plaintiff is TERRY KEITH JONES, who currently resides at an undisclosed
The Defendant is BERNADETTE JONES, who currently resides at 657 Red Fox
Court, Lewisberry, York County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on April 15, 1967 at Towsen, Maryland.
COUNT I - DIVORCE
5. Paragraphs 1 through 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, Sections
3301(c) and 3301(d), in that:
a) The marriage is irretrievably broken.
b) Plaintiff and Defendant have lived separate and apart since January
14, 2002 and continue to do so.
8. The 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.
9. Defendant is not a member of the armed services.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
COUNT H - EQUITABLE DISTRIBUTION
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as
though set forth in full.
11. Plaintiff and Defendant have acquired property, both real and personal, during their
marriage from April 15, 1967 until January 14, 2002, the date of their separation, which property
is "marital property".
12. Plaintiff and Defendant may have owned, prior to the marriage, property which has
increased in value during the marriage and/or which has been exchanged for other property, which
has increased in value during the marriage, all of which property is "marital property".
13. Plaintiff and Defendant have been unable to agree as to an equitable division of said
property prior to the filing of this Complaint.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital
property.
Date
Respectfully submitted,
Austin F. Grogan, ~squ' eff~/
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
I.D.//59020
VERIFICATION
I, TERRY KEITH JONES, verify that the statements made in the foregoing 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