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HomeMy WebLinkAbout04-5991IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Mycal Delando Dickson, Plaintiff 460 Sumner Road, #21 Carlisle, Pennsylvania 17013 422-25-3189 Tiffany Diane Dickson, Defendant 58th Signal BN. Japan, AP 324-82-2998 § CIVIL ACTION - LAW § . § TERM § CASE N0. § IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court for: ® Divorce ? Support ? Division of Property ? Temporary Alimony ? Costs ? Annulment of Marriage ? Custody and visitation ? Alimony ? Attorney You have been sued in Court. If you wish to defend against the claims set forth on the other side of this page, 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 this paper by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of you child or 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 at the CUMBERLAND County Courthouse, in Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OF 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. Office of the Prothonotary CUMBERLAND County Courthouse Telephone( ) . IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Mycal Delando Dickson, Plaintiff § CIVIL ACTION - LAW 460 Sumner Road, #21 § Carlisle, Pennsylvania 17013 § 422-25-3189 § TERM § CASE NO. Tiffany Diane Dickson, Defendant § 58th Signal BN. § Japan, AP § 324-82-2998 § IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Mycal Delando Dickson who resides at; 460 Sumner Road, #21; Carlisle, Pennsylvania 17013. 2. Defendant is Tiffany Diane Dickson who resides at: 58th Signal BN.; Japan, AP. 3. Plaintiff is an active member of the United States Armed Forces and has either maintained his residency in or has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to commencement of this action. 4. Plaintiff married Defendant on November 17, 2002 at Roselawn, Jasper County, Indiana. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Both Plaintiff and defendant are in the military service of the United States within the provisions of the Service Member's Civil Relief Act of 2003. 6. There has been no prior action of divorce or for annulment between the parties. Complaint for Divorce; Page 1 7.The marriage is irretrievably broken. 8. After 90 days have elapsed from the date of filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in marriage counseling. 10. There are no children born to or adopted by the parties to this marriage and none are expected. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed form the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and Defendant. COUNT II REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) AND 3323(6) OF THE DIVORCE CODE. Paragraphs 1-10 are incorporated herein and made a part hereof by reference as though fully set forth. The parties have entered into a written Marital Settlement Agreement providing for the distribution of their property, debts, and spousal support, a copy of which is attached hereto and incorporated by this reference the same as if fully set forth at length. Complaint for Divorce; Page 2 WHEREFORE, Plaintiff respectfully requests that this Court approve and incorporate the agreement reached between the parties into the final divorce decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code. Mycal Delando Dickson I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of the 18 Pa.C.S. Section 4094 relating to unsworn falsification to authorities. Date: Mycal Delando Dickson, Pro Per 72 _7 Y r ! : ,..., . In S ?r ClJ `i7 l "n c.rs 13 ..rte -r" 0 IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF CUMBERLAND COUNTY PENNSYLVANIA Mycal Delando Dickson, Plaintiff § 460 Sumner Road, #21 § Carlisle, Pennsylvania 17013 § 422-25-3189 § Tiffany Diane Dickson, Defendant § 58th Signal BN. § Japan, AP § 324-82-2998 § CIVIL ACTION - LAW TERM CASE NO. 3991 IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Mycal Delando Dickson, being duly sworn according to Law, deposes and says that Plaintiff knows by Plaintiffs own personal knowledge and therefore avers that the defendant, Tiffany Diane Dickson, is 22 years of age and resides at 58th Signal BN., Japan, AP ; that Defendant is not in the military service of the United States or its allies, or otherwise within the provision of the Service Member's Civil Relief Act of 2003 and that the defendant is employed by United States Army. Date: A c^? Ne fi ?ycalando Dickson, Plaintiff Sworn to and subscribed before me this the day of 00-el . "7 r Y P E a?? -ram- (- ??, ak Notary Public 1-11.) . st q r 1- , 4 -c 47 Curtis R. Long Prothonotary (Office of the protbonotarp Cumber[anb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor eW - .457!?91 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573