HomeMy WebLinkAbout01-4987VIRGINIA LEE CONNER,
Plaintiff
JOHN WILBUR CONNER, III,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
: Civil Action - 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 courL A judgment may also be entered
against you for any claim of 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 grounds 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 Bar Association, 2
Liberty Avenue, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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, PA 17013
(717) 249-3166
VIRGINIA LEE CONNER,
Plaintiff
JOHN WILBUR CONNER, Ill,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO, ,o?
........ m ~:)1- .Z/~?o
: Civil Action - In Divorce
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN NAMED DEFENDANT:
You have been named as the Defendant in a divome proceeding filed in the
Court of Common Pleas of Cumberland County, Pennsylvania. This notice is to advise
you that in accordance with Section 3302(d) of the Divorce Code, as amended, you may
request that the Court require you and your spouse to attend marriage counseling prior to
a Divorce Decree being handed down by the Court. A list of professional marriage
counselors is available at the Office of the Prothonotary, Cumberland County Courthouse,
Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and
you are not bound to choose a counselor from the list. All necessary arrangements and
the cost of counseling services are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for
counseling within twenty (20) days of the date on which you receive this Notice. Failure
to do so will constitute a waiver of your right to request counseling.
VIRGINIA LEE CONNER,
Plaintiff
JOHN WILBUR CONNER, III,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO .....t
: Civil Action - In Divome
COMPLAINT
COUNT I - Divorce 23 Pa. C.S.A. §3301(c)
1. Plaintiff Virginia Lee Conner, is an adult individual residing at 916 Bonny
Lane, Mechanicsburg, Pennsylvania 17055.
2. Defendant John Wilbur Conner, III, 916 Bonny Lane, Mechanicsburg,
Pennsylvania 17055.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania and have resided therein for a period in excess of six (6)
months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on November 21, 1998 in Pulaski
County, Arkansas.
5. Plaintiff avers that the ground upon which this action is based is that the
marriage is irretrievably broken.
6. There have been no prior actions of divorce between the parties in this
or any other jurisdiction.
7. The Defendant is not a member of the Armed Services of the United
States of America.
8. The marriage is irretrievably broken.
9. Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to request that the court require the parties to
counseling.
of Divorce.
participate in
10. Plaintiff avers that there are no children born of this marriage.
WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree
Respectfully submitted,
FENSTERMACHER AND ASSOCIATES, P.C.
DATED: August 23, 2001
By:
Ma'rk K. Emery
Supreme Court I.D. #72787
5115 East Trindle Road
Mechanicsburg, PA 17050
(717) 691-5400
Attorney for Plaintiff
2
VERIFICATION
I, Virginia Lee Conner, have read the foregoing Complaint and hereby
certify that the facts set forth are true and correct to the best of my knowledge,
information and belief. This statement is made subject to the penalties of 18 Pa. Const.
Stat. Ann. §4904 relating to unswom falsification to authorities.
DATED:
Vi-[~inia Le~ Conner
FENSTERMACHER AND ASSOCIATES, P.C.
THE JONAS RUPP HOUSE
VIRGINIA LEE CONNER,
Plaintiff
' IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
v. NO, 01-4987 CiviITerm
JOHN WILBUR CONNER, III,
Defendant
· Civil Action - In Divorce
ACCEPTANCE OF SERVICE
I, John Wilbur Conner, III, Defendant in the above-captioned matter, hereby
accept service of the Complaint Jn Divorce in full satisfaction of the Pennsylvania Rules
of Civil Procedure.
Date:
~djohn Wilbur Conner,
IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Virginia Lee Conner :
Plaintiff :
Vs : File No.
:
John Wilbur Conner III :
Defendant :
01-4987
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/defendant in the above matter,
[select one 6y marking "x"]
__ prior to the entry of a Final Decree in Divorce,
or x after the entry ora Final Decree in Divorce dated December 11, ,2001
hereby elects to resume the prior surname of Allen , and gives this
written notice avowing his / her intention pursumf~to the provisions/)of 54 P.~. 704.
Date: April, 28, 2004 !//~A,~,~/ff,!.~,~ .~__~_~ (~/~
t{ Signature - '
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF _C_mahe, xlaad_O
On the 28tlllay of April ,200_~4, belong' me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal. ~,c/~' ~/. ~-~)f~
~OMMONWE~,LTH OF PI:NNSlrVANiA Notary Public
'"Y ~'J'~ ~ ~uflo 27, 2007