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Home My WebLink About06-0082 II LEROY C. JEFFERYS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. ,j()O(p- f.? IN DIVORCE SUSAN A. JEFFERYS, Defendant NOTICE TO DEFEND 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 Court House, Carlisle. Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, SHUFF, FLOWER & LINDSAY 7 :.-:- SAlOIS SHUFF, FLOWER & LINDSAY A1TORNEYS-AT-LAW 26 W. High Street Carlisle, P A Carol J. Lind ay, Supreme Co No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 . SAIDlS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A LEROY C. JEFFERYS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 6'--1-<.. IN DIVORCE v. SUSAN A. JEFFERYS, Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Leroy C. Jefferys, an adult individual residing at 277 Montebello Farm Road, Duncannon, PA 17020. 2. The Defendant is Susan A. Jefferys, an adult individual residing at 277 Montebello Farm Road, Duncannon, PA 17020. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 25, 1984 in New Cumberland, Cumberland County, Pennsylvania. 5. The parties separated on October 29, 2005. 6. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 7. The marriage is irretrievably broken. . SAIDIS SHUFF, FLOWER & LINDSAY AlTORNEYS'AT'LAW 26 W. High Street Carlisle. PA II WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with 93301 of the Pennsylvania Divorce Code. SAIDIS, SHUFF, FLOWER & LINDSAY VERIFICATION I verify that the statements made in the foregoing document are true and correct I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsifications to authorities. L~ff;j1Y Date: I t/ U ( D~ lEe 11m ~ "- "J ~ ~ " ~ "'" ~ ~ ........ 't-..j ~ ~ -........ --D C> ~ ~ r ::> , ~ "" ---e (!) C) ('~ '_0 c:.~ (-.::-~ <:;-.. o .1 .-~ ~;~ f1;~ "T' C? I .:;:- c) ::2 i-":' -jll '-.-' '? ~"!J ::< v' J.;:- SAIDIS, FLOWER & LINDSAY AlTOIlM.,'S...;T'LA\\' 26 \,\rcst High Street Carlisle, PA . LEROY C. JEFFERYS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-82 v. SUSAN A. JEFFERYS, Defendant IN DIVORCE PETITION TO TRANSFER AND NOW, comes Carol J. Lindsay, Esquire, Attorney for Plaintiff in the above captioned action, and avers the following: 1. Both Plaintiff and Defendant are residents in Perry County, Pennsylvania. 2. The Divorce Complaint was erroneously filed in Cumberland County, Pennsylvania. 3. The Courts of Cumberland County do not have jurisdiction over this matter. WHEREFORE, Carol J. Lindsay, Esquire, Attorney for Plaintiff, hereby prays your Honorable Court for an Order directing the Prothonotary to transfer the divorce action to Perry County, Pennsylvania, for filing in that jurisdiction, and to close the within case docketed to 2006- 82, in Cumberland County, Pennsylvania. SAlOIS, FLOWER & LINDSAY ) -, I Carol J. Lindsa Supreme Court 0, 44693 26 West High Street Carlisle, PA 17013 717-243-6222 SAlOIS, FLOWER & LINDSAY ATIURNEYS-AT>lAW 26 West High Street Carlisle, PA II CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Steven Howell, Esquire 619 Bridge Street New Cumberland, PA 17070 SAlOIS, FLOWER & / Carol J. Lindsay, ire Supreme Cou I o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 (2 c_ \-") "\1 :-::J f;'-'. (..) ,I" (,) I :J --~ r-.) ()'. '" SAlOIS, FLOWER & LINDSAY ATI\lRNEYS'ANAW 26 West High StT~et Carlisle, FA 'J... ... iI"" ,10; r,J ] 7 LUUb. LEROY C. JEFFERYS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-82 v, SUSAN A. JEFFERYS, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ~ day of ~~ ~ ... of Carol J, Lindsay, Esquire, Attorney for Plaintiff, the Prothonotary of Cumberland County is ,2005, upon the Petition hereby directed to transfer the above captioned case to the Prothonotary of Perry County, Pennsylvania, and to close the case docketed to No. 2006-82, in Cumberland County, Pennsylvania. J. BY THE CO~/ {/ ~/ ~~ 0' .2> b: C"') 0 4- ,... ...::r 0 l,U -;:"' 0'-' 0:: --c, H--=:t~ (-)1- . 0 @O (1'': cry i- 0- ...-ft... "'- U:fS .'::C. -1 -, ,,-". ...0 ~'.. - LL (.",;;:} :.::> 0 ,;,:;;:, 0 "'"