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HomeMy WebLinkAbout06-0418 BARBARA A. FENICLE, IN THE COURT OF COMMON LEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006- 4i P CIVIL JASON P. FENICLE, SR. CIVIL ACTION-LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the cl ims set forth in the following pages, you must take prompt action. You are warned that if yo fail to do so, the case may proceed without you and a decree of divorce or annulment ma be entered against you by the court. A judgment may also be entered against you for any ,her claim or relief requested in these papers by the Plaintiff. You may lose money or prop rty or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable brea down of the marriage, you may request marriage counseling. A list of marriage coun elors is available in the Office of the Prothonotary at the Cumberland County Court House, arlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULM NT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONC . IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA ION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY FFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FE . Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 BARBARA A. FENICLE, Plaintiff V. JASON P. FENICLE, SR. Defendant IN THE COURT OF COMMON LEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2006- q17 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Barbara A. Fenicle, an adult individual who curr( Mooredale Road, Apartment 1, Carlisle, Cumberland County, Pennsylvs 2. Defendant is Jason P. Fenicle, an adult individual who cur Prospect Road, Carlisle, Pennsylvania 17013-9786. 3. Plaintiff and Defendant have been bona fide residents in ti Pennsylvania for at least six months immediately previous to the filing o' 4. The Plaintiff and Defendant were married on April 29, 199 Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulm resides at 88 is 17013-9322. ntIv resides at 67 Commonwealth of his Complaint. in Carlisle, it between the parties. 6. The marriage is irretrievably broken. 7. The 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 i Counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. COUNT II -EQUITABLE DISTRIBUTION 9. Plaintiff hereby incorporates by reference paragraphs 1 thrc 10. The parties have acquired real estate, personal property, in, bank accounts and other items of miscellaneous property during the cour some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court which effects an equitable distribution of marital property. Respectfully submitted, O'B?jRRIIIEN, BAA?RJICC & SCHERER Date: January 19, 2006 Michael A. Scherer, Esquire LD.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff, Barbara A. Fenicle 18 above. ling automobiles, of their marriage, to enter a decree maslDomesticlFenicleld ivorce.comp BARBARA A. FENICLE, Plaintiff V. JASON P. FENICLE, 5 Defendant IN THE COURT OF COMMON LEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- CIVIL TERM CIVIL ACTION-LAW IN DIVORCE VERIFICATION I verify that the statements made in this Divorce Complaint are tru( understand that false statements herein are made subject to the penalties c § 4904, relating to unsworn falsification to authorities. Barbara A. and correct. 1 A 18 Pa. C.S.A. Date: January J? , 2006 ?.: r ? ' ^ ''J . _. ?., c "`? -' ti T? ? ? ? ?, ir? ?? ?. , i T r-- ?'? Curtis R. Long Prothonotary Office of the Protbonotarp Cutnberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 101p - q19 CVIL TERM 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