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Home My WebLink About06-2193F:\FILES\DATAFILE\Ceneml\Cuuent\I2061. I-com Created: 9/20104 0:06PM Revised 4/18/06 3 :47PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff WAYNE M. FUSS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06- , l y3 (7( 0 CIVIL ACTION - LAW DAWN M. FUSS, Defendant : 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 maybe entered against you by the Court. A judgment may also be entered against you for any other claim orreliefrequestedinthese papers bythePlaintiff. 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 ofthe marriage, you may request marriage counseling. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OREXPENSES BEFORE A DIVORCE ORANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPERTO YOURLAWYERAT ONCE. IFYOU 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION 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, Pennsylvania 17013 Telephone (717) 249-3166 WAYNE M. FUSS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA V. NO. 06- CIVIL ACTION - LAW' DAWN M. FUSS, Defendant : IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C) or D) Plaintiff is Wayne M. Fuss, who currently resides at 65 Aspen Road, Dillsburg, Pennsylvania 17019. 2. Defendant is Dawn M. Fuss, who currently resides at 1 North Baltimore Street, Franklintown, Pennsylvania 17323. 3. Plaintiffand Defendant have been bona fide residents in the Commonwealth ofPennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 16, 1997. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The parties have been separated and living apart since December, 2003. 8. Plaintiffhas 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. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage between Plaintiff and Defendant. MARTSON DEARDORFF WILLIAMS & OTTO Jennifler Spears, Esquire 10E ast igh Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: April 18, 2006 VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation ofthe lawsuit. The language ofthe document is that ofcounsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best ofmy knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that ifI make knowingly false averments, I may be subject to criminal penalties. Wayne M. Figs F \FILES\DATAFILE\G.,,N\Cunurt\12061.1 co. \?? ?. ?-?' ?. -?, ?' ?. ?., ryJ i? rt a _., _ _ ?i1 '? ?_ ? F:\FILES\DATAFILE\Gene al\Curtent\12061.1 aos C,eated: 9/20/04 006PM Revised 4126/06 828AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff WAYNE M. FUSS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-2193 CIVIL ACTION - LAW DAWN M. FUSS, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Dawn M. Fuss at P.O. Box 177, Franklintown, PA on April 20, 2006, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Dawn Fuss" and dated April 24, 2006. Jen if L. Spears, Esquire Sworn to and subscribed before me this yU41 ay of April, 2006. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Melissa A. Scholy, Notary Public Carlisle Born, Cumberland County My Commission Expires Jan. 19, 2010 Member, Pennsylvania Association of Notaries Postal M CERTIFIED MAILT,, RE CEIPT (Domestic Mail Only , No insurance coverage Provided) ru 5 CD F iL i. N t#+9 7 M Postage s O certified Fee O Racmpt (Endorsement nt Required) pr 7 ? M1 Lr) f festdoted Delivery Fat, (Fntlarsemeni Required) 1?. r!1 n .y .,?n ru Total Postage &Fee, ,$ $$.Jli IT1. ;?,;n?1?f 1; 1,l Sent TO M,,. /? _. Sheet, Apt. No.; // or PO Box NO. ,_/-yr / .. ../.. 77 7? TZ3 PS Form 3800, Julie rr ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Pv b? X77 A 11 ecelved by (Printed Name) C. Date of Delive ?w? Fuss 1/-2Y-/V D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Spivica Type fled Mall 0 Express Mall ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) 119 Yes 2. Article sfer Number 7005 2570 0000 3802 8436 (hans/er ft m seMCe label) Ps Form 3811, February 2004 Domestic Return Receipt 102595-02-M-160 ?? o? r??? r s> _._ - . ?? .- Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberlanb Cnuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor JOL -,( 93 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