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
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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
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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