HomeMy WebLinkAbout02-0787LINDSEY M. BISHOP,
Plaintiff
Vo
BRYAN K. BISHOP,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION o LAW
:
: NO. 0 ;t. '7 ~' 3 CIVIL TERM
: 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
will proceed without you and a decree of divome or annulment may be entered against you for
any 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 the divome 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 Cumberland County Courthouse, Carlisle, Cumberland County,
Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
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
Two Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
LINDSEY M. BISHOP,
Plaintiff
Vo
BRYAN K. BISHOP,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: NO. b,~- 9 ~' '7 CIVIL TERM
: IN DIVORCE
COMPLAINT IN DIVORCE
NO FAULT
Plaintiff is Lindsey M. Bishop, an adult individual currently residing at 181 Brindle
Drive, Mechanicsburg, Cumberland County, Pennsylvania.
Defendant is Bryan K. Bishop, an adult individual currently residing at Cumberland
County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania.
o
Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been
so for at least six months immediately previous to the filing of this Complaint.
Plaintiff and Defendant were married on March 3, 2001, in Landisburg, Perry
County, Pennsylvania.
5. There have been no other prior actions for divorce or annulment between the parties.
Neither the Plaintiff nor the Defendant are members of the United States Armed
Forces or its Allies.
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.
10.
Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90)
days from the date of the filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23
P.S. Section 3301 (c) of the Domestic Relations Code.
11.
COUNT II
Paiagraphs 1 through 10 arc incorporated herein by reference as if set forth in their
full text.
12. Defendant has committed such indignities upon the person of the Plaintiff, the
innocent injured spouse, as to make her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23
P.S. Section 3301(a)(6).
Respectfully submitted,
Maryl~Ut/~tasl Esquir~~
Attorney~ogPlaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are tree and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unswom falsifications to authorities.
DATE:
- BISHOP
LINDSAY M. BISHOP,
Plaintiff
BRYAN K. BISHOP,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: NO. 0~'~ 0']~'~ CIVILTERM
: IN DIVORCE
CERTIFICATE OF SERVICE
I, Marylou Matas, Esquire, hereby certify that I did, the I.i~9t day of February, 2002,
cause a copy of Plaintiff's Complaint In Divorce to be served upon Defendant by personal
services at the Cumberland County Courthouse, Carlisle, Pennsylvania.
DATE: Z/I ~.z/0 Z.
ry ouk..~atas, Esquire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800)347-5552