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HomeMy WebLinkAbout05-1647F9Fl LF.SVUnl'AFILEVCeueralAC wrem\11371.34. aim Geatad: 3i33105 3:33PM Revised: 3/33/05 3:49PM Jennifer L. Spears, Esquire I.D. 87445 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KENNETH STERLING, JR. Plaintiff V. CHERYL STERLING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (OS- ! 6 q -7 CIVIL ACTION - LAW 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 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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 HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 KENNETH STERLING, JR. Plaintiff V. CHERYL STERLING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Kenneth Sterling, Jr., who currently resides at 612 Range End Road, Lot 81, Dillsburg, Pennsylvania 17019. 2. Defendant is Cheryl Sterling, who currently resides at 50 Spring Garden Road, Carlisle, Pennsylvania 17013 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 6, 1989, in York County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. MARTSON DEARDORFF WILLIAMS & OTTO By Jenni er . Spears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: 3lTct(05 Attorneys for Plaintiff r VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Divorce Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subj ect to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. enneth L. Sterling, Jr. F \FILES\DATAFILE\General\Cu rent\11371.34.com J n r ? d -c? / Y Clnl Ed 32310511/05 3333nere?CurtenrA111]134.nos Geotcd 4, 00M Revard 4:5105 1006AM Jennifer L. Spears, Esquire I.D. 87445 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KENNETH STERLING, JR. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05-1647 CIVIL ACTION - LAW CHERYL STERLING, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND SS. 1 hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Cheryl Sterling at 50 Spring Garden Road, Carlisle, PA 17013 on March 30, 2005, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed " Cheryl Sterling" and dated March 31, 2005. Jennif r *LSpars, Esquire Sworn to and subscribed before me this ZL day of April, 2005..}I11 L,? 1 l Not?tt?ubl e COMMONWEALTH OF PENNSYLVANIA Notarial Seal Carlisle or o, rCu berland Pjb"c Countyy My Commission Expires Aug. 18, 2t Member, Pennsylvania Asso,ofion of Nolaoes a O D HI-TOUTIORRI MWA r == v .?ty?? f? Ill Postage Y.•? $ ie1•X CorNied Fee i? O , Return ReclePt Fee •. • a rk ED (Endorsement Required) 'n ( P ' M Restricted DelNery Fee {8•Qp . (Endoreemeni Raquned) ri 12 ??, M Total Postage & Fees ,$ v fTl Sent To nn O c. ----°-- .....-. ------------ --- -v? -- --------?--f}-- orPoaoxNa ?y city, -•--- state, --.....? .. . .......... .-....?---.....----.. cry, zIP«4 ? U / , rr ¦ Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. t Attach this card to the back of the mailplece, or on the front If space permits. 1. Article Add to: Ind- 64 A SJGGe?re 0 Agent dre x ddre L/T l.QJ?/.?J ? A B. Received bV(Pdnted Name) 10. Date of PSI D. Is delivery address different from item 1?? as If YES, enter delivery eddreas bebw: No 0 ;PR ea'46 site pet /701,3 3. Service Type arCerthled Mail 0 Express Malt 0 Registered 0 Return Receipt for Merchandise 0 Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) .l$' yes 2. Artble Number (mmsrernomservice lebag 7003 3110 0004 5772 6792 PS Form 3811, August 2001 Domestic Return Receipt IMS9542-nt:t540 ?^7 10 Curtis R. Long Prothonotary office of the i9rotbonotarp Cumberrarib Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor DS - 11, Lf I CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 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