HomeMy WebLinkAbout05-4413CHARLENE O. GLASSMYER,
Plaintiff
V.
ERIC L. GLASSMYER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. DS - ?J?//3
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 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 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, PA 17101.
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.
LAWYER REFERRAL SERVICE
32 South Bedford Street
Carlisle, PA 17013
"(717)249-3166
MCNEES WALLA E & NURICK LLC
By
ra D.
I.D. #66378
100 Pine Street, P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
CHARLENE O. GLASSMYER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. Ds - qy3
ERIC L. GLASSMYER, JR.,
Defendant IN DIVORCE
COMPLAINT
And now comes Plaintiff, Charlene O. Glassmyer, by and through her counsel,
McNees Wallace & Nurick LLC, and files the following Complaint in this matter.
COUNTI
Divorce Under 3301(c) or 3301(d) of the Divorce Code
1. Plaintiff is Charlene O. Glassmyer who currently resides at 475 Brook
Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is Eric L. Glassmyer, Jr. who currently resides at 5015 Lenker
Street, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months previous to the filing of this
Complaint.
4. Plaintiff and Defendant were married on May 18, 1991 at Cumberland
County, Pennsylvania.
5. The parties are the parents of one minor child, Audrey Lynn Glassmyer,
born on December 2, 1998.
6. There have been no prior actions of divorce or annulment between the
parties.
7. The marriage is irretrievably broken.
8. The grounds on which the action for divorce is based are:
A. Section 3301(c): The marriage of the parties is irretrievably broken.
After 90 days have elapsed from the filing of this Complaint, it is believed the parties will
file Affidavits of Consent to a divorce.
B. Section 3301(d): At the completion of the two year waiting period,
Plaintiff shall file the necessary affidavits for finalization.
9. Plaintiff has been advised of the availability of counseling and that she
may have the right to request that the Court require the parties to participate in
counseling. Plaintiff hereby waives her right to such counseling.
10. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under
Section 3301(c) or (d) of the Divorce Code.
COUNT 11
Equitable Distribution
11. During the marriage, Plaintiff and Defendant have acquired various items
of marital property and various debts, which are subject to equitable distribution under
Sections 3501 and 3502 of the Divorce Code.
12. Plaintiff and Defendant have not agreed to an equitable distribution of this
property and debt.
-2-
13. Plaintiff requests the Court to equitably distribute all the property and debt.
WHEREFORE, Plaintiff requests the Court to enter an Order equitably dividing
all of the marital property and debt.
McNEES WALLACE & NURICK LLC
By
D. Qn-Sn'tor
?Tt. # 6637
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff
Dated: August 25, 2005
-3-
VERIFICATION
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.
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Charlene O. Gtassmyer
Dated: K17-410-5
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CHARLENE O. GLASSMYER,
Plaintiff
V.
ERIC L. GLASSMYER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-4413 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint.
Eric L. Gins myer,
Date: y/11,12s
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Curtis R. Long
Prothonotary
office of the Vrotbonotarp
CCumbprlanb CCouutp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
5 -'jy 1.3 CVIL TERM
-10 ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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