HomeMy WebLinkAbout05-2391BARBARA HARLEY,
Plaintiff
VS.
MICHAEL HARLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. DE -d0?/
CIVIL ACTION - AT 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. A list of marriage counselors is available in the Office of
the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania.
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.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
800-990-9108
BARBARA HARLEY.
Plaintiff
VS.
MICHAEL HARLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. QS -4? Ctv
CIVIL ACTION-AT LAW
IN DIVORCE
AND NOW, comes the above captioned Plaintiff, Barbara Harley, by and through her
attorneys, The Law Offices of Patrick F. Lauer, Jr., L.L.C., and seeks to obtain a Decree in Divorce
from the above named Defendant, Michael Harley, upon the grounds hereinafter set forth:
The Plaintiff, Barbara Harley, is an adult individual who currently resides at 24
West Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant, Michael Harley, is an adult individual who currently resides at 24
West Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. The Parties have been bona fide residents of the Commonwealth of Pennsylvania for
at least six (6) months immediately prior to the filing of this Complaint.
4. The parties were married on August 16, 1992, in Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Plaintiff avers that the marriage is irretrievably broken.
7. The 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. This action is not collusive.
WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in
this matter.
Date;
J 5eph D. CarWolo, Esquire
w Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
IN 90919 Tel. (717) 763-1800
BARBARA HARLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No.
MICHAEL HARLEY, CIVIL ACTION - AT LAW
Defendant : IN DIVORCE
I ?....14dCAT.01TMd
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom
falsification to authorities.
Signature: _ &WZ44?
BARBARA HARLEY 61
Date: /?? 005
BARBARA HARLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No.
MICHAEL HARLEY, CIVIL ACTION - AT LAW
Defendant : IN DIVORCE
I accept service of the foregoing Complaint in Divorce. I certify that I am authorized to
accept service on behalf of the above captioned defendant.
Date
Defendant or Authorized Agent
Mailing Address
r^ crr
(?
lf7 l Cam'
) i
C C R
Ui `?
Curtis R. Long
Prothonotary
(Office of the Vrotbonotarp
Cumberfanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
0.5- 2,39 ( 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