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HomeMy WebLinkAbout05-3339 Tammy Ann Alexander, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Bruce Alexander, Jr., Defendant CIVIL ACTION - LAW NO. 05 - 133 <1 IN DlVORl:E CIVIL TERM You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff, You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION 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, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Tammy Ann Alexander, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Bruce Alexander, Jr., Defendant CIVIL ACTION - LAW NO. OS - . ~33'1 IN DlVOR~E CIVIL TERM COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Tammy Ann Alexander, an adult individual, who resides at 156 Chamberlin Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Bruce Alexander, Jr., an adult individual, who resides at 4155C McClays Mill Road, Shippensburg, Franklin County, Pennsylvania 17257, 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4, Plaintiff and Defendant were married on April 17, 2004, Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate, Respectfully submitted, ROMINGER, BAYLEY & WHARE ro~l1~ch Date: Mark F. Bayley, Esquire 155 S. Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court I.D, # 87663 Attorney for Plaintiff VERIFICA TION 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 unsworn falsification to authorities. ;),1, {)"~ , Date~IUU '- -0 ~ J1 ~~ ~ -- - -- ~ ~ w ~ , Ct ~ u-, \ IV ~ ~ 2 ;':. -c\-r~ fflfn z.-r.' zi.:., CfJ:, ,,'";~ ;::.,;_. iLC) - - ~g YC: 3. " ~ Q, ~ ~ ~~~ v:> '00 a (:Jh -1>;', ~ %~ :::: :::'I ~ ~ -I ~ Tammy Ann Alexander, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Bruce Alexander, Jr., Defendant CIVIL ACTION - LAW NO. 05. 3339 CIVIL TERM IN DIVORCE PRAECIPE TO WITHDRAW Please withdraw the Divorce Complaint the above captioned matter on behalf of the Plaintiff, Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: ;::z...?~-=- D$' MfJdJil... (") .-> () ,00;> <;;, ..:::- ." cJ' <- ~1:D c-:; ,- r'- f'} "'"11"" ~,,'lC} 0' .:"'1 (!.-) ,',3-1', c ,_:',2~\; - ;,.~n\ , - ~, ..-1 .A.'~" ?1s :;~ <~, (,n ..<: -