HomeMy WebLinkAbout04-46510
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
KENNETH L. EDSALL, NO. 04-
plaintiff TIC
Plaintiff 1
vs.
CIVIL ACTION - LAW
LYNNE T. EDSALL,
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 relief requested in these
papers by the Plaintiff. You may lose money or property or other rights important to you.
When the grounds for the 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 Court House, 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
ASSISTANCE.
Court Admiaiatrator
Fourth Floor
Cumberland County Courthouse
One Court House Square
Carlisle, Pennsylvania 17013-3387
Telephone: (717) 2406200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
KENNETH L. EDSALL, NO. 04- 4 145?1
Plaintiff
vs.
CIVIL ACTION - LAW
LYNNE T. EDSALL,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, this _,(&_ day of 5e/'7em y,r g , 2004 comes the Plaintiff,
KENNETH L. EDSALL, appearing pro se, who files the following Complaint in Divorce
averring as follows:
1. The Plaintiff, KENNETH L. EDSALL, is an adult individual currently residing at
4201 Gettysburg Road, Lot 8, Camp Hill, Cumberland County, Pennsylvania 17011.
2. The Defendant, LYNN T. EDSALL, is an adult individual currently residing at 4201
Gettysburg Road, Lot 8, Camp Hill, Cumberland County, Pennsylvania 17011.
3. The parties have no minor children.
4. Plaintiff and Defendant were married on or about June 25, 1983, in Newport, Perry
County, Pennsylvania.
5. Plaintiff and Defendant separated and ceased living as husband and wife on or about
May 1, 2004.
6. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately prior to the filing of this
Complaint.
7. There have been no prior actions of divorce or annulment between the parties.
8. 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.
9. Both the Plaintiff and Defendant are sui juris and are citizens of the United States.
10. The Plaintiff avers that the grounds on which the action is based are that the marriage
is irretrievably broken.
WHEREFORE, Plaintiff requests that this Honorable Court enter a Decree in
Divorce, in accordance with section 3301(c) or (d) of the Divorce Code (23 Pa.C.S. Sec.
101 et seq.).
Respectfully submitted:
?4,vA d .cCJd4W
Kenneth L. Edsall
4201 Gettysburg Road, Lot 8
Camp Hill, PA 17011
(717) 919-4"5 2638
Appearing pro se
VERIFICATION
1, KENNETH L. EDSALL, state that I am the PLAINTIFF in the foregoing
COMPLAINT and that the facts set forth therein are true and correct to the best of my
knowledge, information, and belief. I realize that false statements herein are subject to
the penalties for unswom falsification to authorities under 18 Pa.C.S. Sec. 4904.
1, zilaa,QP
Kenneth L. Edsall
Date: 9"14'6 Z/
?`?
Renee K. Simpson
Deputy Prothonotary
Curtis R. Long
Prothonotary
f t e yr o,tbwaotarP
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(Cutnberlanb Countp
John E. Slike
solicitor
5 CIVIL TERM
ER OF TERMINATION OF COURT CASES
ORD
IvIBER 2007 AFTER MAILIN ? Ag?V OF
TH DAY OF HOVE 5PONSE ANCE WITH PA
AND NOW THIS 5 CE?tING NOIRE ACCORD
INTENTION TO Y ?E IN TA D WITH PREND
CASE IS HEREB
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
ns lvania 17013 • (717) 240"6195 • Fax (717) 2`10-6573
n.,P Courthouse Square 'Carlisle, Pen Y