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HomeMy WebLinkAbout05-3742DIANE STAHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. y 5- _ '?7`?-Z- L"emu b lv . JACK STAHL, : CIVIL ACTION - AT LAW IN DIVORCE Defendant 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 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, Harrisburg, 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 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 DIANE STAHL, Plaintiff V3. JACK STAHL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. OS- 3,7 -12- CIVIL AM ACTION - AT LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above captioned Plaintiff, Diane Stahl, 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, Jack Stahl, upon the grounds hereinafter set forth: 1. Plaintiff is Diane Stahl, an adult individual, who currently resides at 127 n. Middlesex Road, Carlisle, Cumberland County, and State of Pennsylvania. 2. Defendant is Jack Stahl, an adult individual, who currently resides at 127 n. Middlesex Road, Carlisle, Cumberland County, and State of Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 24, 1990, in Cumberland County, Pennsylvania. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. The Plaintiff and Defendant are both Citizens of the United States of America. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. 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. 9. The Plaintiff avers that the marriage is irretrievably broken. WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter a Decree in Divorce. Respectfully submitted, Dated o? C? J/'/ph D. Caraciolo, Esquire A 08 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 90919 Tel. (717) 763-1800 DIANE STAHL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. JACK STAHL, : CIVIL ACTION - AT LAW IN DIVORCE Defendant VERIFICATION I verify that the statements made in this Complaint for Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. i S Signature: Date: Diane Stahl N V W F Curtis R. Long Prothonotary office of the protbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 05- 37y;L, 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