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Home My WebLink About05-3131 . STEVEN D. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . : NO. DS - 2/31 CIVIL TERM REBECCA S. LONG, Defendant : CIVIL ACTION-LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claim 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 plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the gro\Uld for divorce is indignities or irretrievable break down of marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's office at the Cumberland CO\Ulty Courthouse, Carlisle, Pennsylvania IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISON 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 TIDS 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 South Bedford Street Carlisle. Pennsylvania 17013 (717) 249-3166 .... STEVEN D. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . : NO.DS- 213/ CIVIL TERM REBECCA S. LONG, Defendant : CIVIL ACTION-LAW : IN DIVORCE COMPLAINT IN DIVORCE The Plaintiff, Steven D. Long, makes the following Complaint in Divorce and in support there of, avers as follows: 1. The Plaintiff, Steven D. Long, is an adult individual who currently resides at 6412 Carlisle Pike, Lot 120, Mechanicsburg, (Silver Spring Township), Cumberland County, Pennsylvania 17050. 2. The Defendant, Rebecca S. Long, is an adult individual who currently resides at 342 East Main Street Apt. A, Everett, Bedford County, Pennsylvania 15537. 3. The Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this complaint. 4. The Plaintiff and the Defendant were married on April 2, 2001 in Bedford County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 7. Plaintiff avers that the grounds on which the action is based are: a. Section 3301 ( c) Mutual Consent No-Fault: The marriage is irretrievably broken; b. Section 3301 ( d ) Non-Consent No-Fault: The marriage is irretrievably broken and the parties are now living separate and apart. Once the parties have lived separate and apart for a period of two years, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. c. Section 3301 ( a ) ( 2 ) Adultery: Defendant has committed adultery. d. Section 3301 ( a) ( 6 ) Indil!nities: Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome, and that this action is not collusive. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff, STEVEN D. LONG, respectfully requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and the Defendant. Respectfully submitted, Date: c./II> J 05" I f ;):viJ~~ \). ,fuv-r Steven D. Long, Plaintiff 6412 Carlisle Pike Lot 120 Mechanicsburg, PA 17050 (717) 265-4846 . STEVEN D. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL TERM REBECCA S. LONG, Defendant : CML ACTION-LAW : IN DIVORCE VERIFICATION I verifY that the statements made in this Complaint are true and correct. I ooderstand that false statements here in are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. ~~ \).~ Steven D. Long '2. 4.A- 7d - ..c \t- C> () \t- lrt 0 - ~ \'" t...; U"l ~ -cJ ()J .c ~ ~ -c.. r II) (}I (} \;::- ~ ~; <(;.":. :,:t:: Q, ....-\ -j:,-<) r'i'\~ ...o.\'~ -):1---< 6"'~) () #~:~ :~~\::i}> ::.~::. ^)':. (1"\ -~?\ o ...,,-, V" t.~:/ ~:~ - - --- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-03131 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LONG STEVEN D VS LONG REBECCA S R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT LONG REBECCA S but was unable to locate Her deputized the sheriff of BEDFORD , to wit: in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT - DIVORCE 28th , 2005 , this office was in receipt of the On June attached return from BEDFORD Sheriff's Costs: Docketing Out of County Surcharge Dep Bedford County Postage 18.00 9.00 10.00 30.60 .74 68.34 06/28/2005 STEVEN D LONG Sworn and subscribed to before me this ,,~ day OfQ,~ .2eo6 A. D. C~'A<~ (;J n,,'Ob. J ~ I Prothonotary' County In The Court of Common Pleas of Cumberland County, Pennsylvania Steven D. Long VS. Rebecca S. Long No. 05-3131 civil Now, June 20, 2005 ,I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of RAr1ford County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. r:~~~~ Sheriff of Cumberland County, PA Affidavit of Service Now, June 22 20 05 at 8: 05 '-' o'clock P M. served the within Complaint in Divorce upon Rebecca S. Long at 342 East Main Street, Apt. A, Everett, PA 15537 by handing to Rebecca, personally a true copy of the original Complaint in Divorce and made known to Rebecca S. Long the contents thereof. So answers, ~i~i;::i31 Bedford County, PA Sworn and ~bscribed before me this a2f nay of .glll'/l 0 , 200.;2, .;1. ~OL ~ rI> II tiod o/i'n; L 0 - s~ fl( p\JtlYC \..N'~~oN~ couNT1 Kt'ttiFORDfWP.ON E~~R~S l1.,o..RCH 5 ~ ~ Cr::J:,\W,\SS\ COSTS SERVICE MILEAGE AFFIDAVIT $ $ STEVEN D. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-3131 CIVIL TERM REBECCA S. LONG, Defendant : CIVIL ACTION - LAW : IN DIVORCE ENTRY OF APPEARANCE To the Prothonotary: Kindly enter the appearance of Linda A. Clotfelter, Esquire, for Defendant, Rebecca S. Long, in the above-captioned proceeding. Respectfully Submitted, LAW FIRM OF LINDA A. CLOTFELTER Date: 7/1) .r /0') I L DA A. CLOTFELTER, ESQUI A orney I.D. 72963 21 E. Trindle Road, Suite 100 Mechanicsburg, P A 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Defendant STEVEN D. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-3131 CIVIL TERM REBECCA S. LONG, Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 015 i'L day of U u.L.~ . 2005, the undersigned hereby certifies that a true and correct copy of the foregoing ENTRY OF APPEARANCE was served upon the opposing party by United States First Class Mail, postage prepaid: Steven D. Long 6412 Carlisle Pike, Lot 120 Mechanicsburg, PA 170150 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER B. Li da A. Clotfelter, Esquire A rney ill No. 72963 1 East Trindle Road, Suite 1 Mechanicsburg, P A 17050 (717) 796-1930 telephone (71 7) 796-1933 facsimile Attorney for Defendant () c r--' c;;':': ~ ef" '--. ';:-~::. " c-~_ ~t N C!" C) ':'n -' .-,:.....n f'l1~ ")?G :J)'~; r-~:~fTl .~:.~\ ~~ -G ::;;;: r:-? .r:- -' NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (117) 241,4436 ATTORNEY FOR PLAlNTlFF STEVEN D. LONG Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : Docket No. 2005-3131 Civil Term REBECCA S. LONG Defendant : CIVIL ACTION - LAW : In Divorce PRAECIPE FOR ENTRY OF APPEARANCE OF COUNSEL OF RECORD Kindly enter the appearance ofNA1HAN C WOlF, ESQUIRE, as attomeyforthe defendant, Steven D. Long, in this matter. / SePteDlber~005 NATIIAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA STEVEN D. LONG Plaintiff V. : Docket No. 2005-3131 Civil Term REBECCA S. LONG Defendant : CIVIL ACTION - LAW : In Divorce CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing entry of appearance upon the following person and in the manner indicated: Linda D. Qotfelter, Esquire 5021 East Trindle Road Suite 100 Mechanicsburg, P A 17050 Attorney for Defendant Dated: September ~ 2005 Respectfully submitted, WOLF & woy'/? 7/ -~ ~.. ~.v Nath\1ii C. ~Esquire 37 Sou~nover Street, Suite 201 Carlisle, PA 17013 Supreme Court LD. No. 87380 (717) 241-4436 Atrorneys for Plaintiff (:? r-' C) C:":'> oJ' <1'1 'T1 ~D I 0-' '. -'7 "';'". Cl -n ..... X--n r;\?3 -n~~i -;J"--,"' ~)C' '<:1...;..', ....<-\'l :~;~~ f) ~-1 -j'.,..... ~.>:J ".< ~? C..fl - .- NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241,4436 ATtORNEY FOR PLAINTIFF STEVEN D. LONG Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. REBECCA S. LONG Defendant : Docket No. 2005-3131 Civil Term : CIVIL ACTION - LAW : In Divorce PRAECIPE TO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Kindly mark the complaint filed in the above-referenced action WlTIIDRA WN, without prejudice to the Plaintiff. DeceD1ber~,2005 WOLF & WOLF NAT C. WOLF, ESQUIRE g.uth Hanover Street, Suite 201 ttisle, PA 17013 717-241-4436 SUPREME COURT ID #87380 Attorneys for Plaintiff ~ " NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241,4436 ATTORNEY FOR PLAINTIFF STEVEN D. LONG Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : Docket No. 2005-3131 Civil Term REBECCA S. LONG Defendant : CIVIL ACTION - LAW : In Divorce CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing praecipe to withdraw the complaint upon the following person and in the manner indicated: Linda D. dotfelter, Esquire 5021 East Trindle Road Suite 100 Mechanicsburg, P A 17050 Attorney for Defendant Dated:December~,2005 Respectfully submitted, WOLF & WOLF // ~'-~ ~Zn Natlliin C.~, F;squire 37 Somlriliinover Street, Suite 201 c:trlfsle, PA17013 Supreme Court J.D. No. 87380 (717) 241-4436 Attorneys for Plaintiff .. - " .._._~..,~.~