HomeMy WebLinkAbout02-1850WARREN T. BATDORF,
SUSAN I. BATDORF,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
: NO0oI'/~),,r)(,3 CIVIL
TERM
: 1N DIVORCE
NOTICE
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, High and Hanover Streets, Carlisle.
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
2 Liberty Avenue
Carlisle, PA 17013
Phone: (717) 249-3166
WARREN T. BATDORF,
SUSAN I. BATDORF,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
: NO. 002-" ] ~k.~"'O CIVIL TERM
: IN DIVORCE
DIVORCE
COUNT I
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Warren Thomas Batdorf, who currently resides at 226 Faith Circle, Carlisle,
Cumberland County, Pennsylvania, since December 1989.
2. Defendant is Susan I. Batdorf, who currently resides at 226 Faith Circle, Carlisle, Cumberland
County, Pennsylvania, since December 1989.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth lbr at least
six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on January 23, 1965, at Union County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in this
or any other jurisdiction.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff requests the Court to enter a Decree of Divorce.
COUNT II - COMPLAINT UNDER SECTION 3301(a)(6)
9. Paragraphs 1 through 8 of this Complaint are incorporated herein by reference thereto.
10. Defendant has offered such indignities to the Plaintiff, who is the innocent and injured
spouse, as to rendered Plaintiff's condition intolerable and the life of Plaintiff burdensome.
11. Plaintiff requests the Court to enter a decree in divorce.
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 unswom falsification
to authorities.
Date:
Warren T. Batdorf, Plaintifff
ANDREWS & JOHNSON
"/ - Ronald-E. foJtf~.~., Esquire
/ Attorneys f~rll~laintiff
~ 78 W. Pord~et Street
Carlisle, PA 17013
(717) 243-0123
WARREN T. BATDORF,
SUSANI. BATDORF,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 02-1850 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND )
AND NOW, this ~ day of April, 2002, I, Ronaid E. Johnson, Esquire, attorney for Warren T.
Batdorf, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the
Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-
captioned matter, upon the Defendant at her residence at 226 Faith Circle, Carlisle, PA 17013, by depositing
the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A
copy of the return receipt card signed by the Defendant on April 22, 2002, indicating service was effected, is
marked Exhibit "A", attached hereto and made a part hereof.
ANDREWS & JOHNSON
Swom,,.~nd subscribed to before me this
0Pu,c - _
MY COMMisSiON EXPIRES APRIL 2~, 2003
tuber, ~
· Complete items 1, 2, and 3. Also complete
item 4 if Restrid~ed Dellvm7 is desired.
· Print your name and address on the reverse
so that we c, an return the card to Y°U'.
· ~.ttach this card to the back ,o~f the manp.~,,
_~r on the front i1 space perm .
('rt~n~f~r ~ ~ tabe0
PS Form 3811, March 2001
D0me~tlc Return Receipt
Exhibit A