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HomeMy WebLinkAbout06-4329IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kathleen Y. Furr Plaintiff VS. Archie L. Furr Defendant NO. CIVIL D` -143.2q CIVIL ACTION - 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 by the court. A judgement 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 grounds 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 Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION 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 OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service 4' floor Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kathleen Y. Furr Plaintiff vs. D (- - 'y3a? l:lc? ??J23 l Archie L. Furr NO. CIVIL Defendant CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) or (d)OF THE DIVORCE CODE The Plaintiff, Kathleen Y. Furr, by and through her attorneys, Gates, Halbruner & Hatch, P.C., makes the following complaint in divorce: 1. Plaintiff is KATHLEEN Y. FURR, an adult individual who currently resides at 817 Flintlock Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is ARCHIE L. FURR, an adult individual who currently resides at 817 Flintlock Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on December 27, 1980, in Mechanicsburg, Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment between the parties except this complaint filed for divorce. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff and Defendant both have the right to request that the court require the parties to participate in counseling. 9. Plaintiff and Defendant did not have any children together during their marriage. 10. Plaintiff and Defendant are owners of various items of real estate or personal property or other items of marital property which is subject to equitable distribution by the court. 11. After ninety (90) days have elapsed from the date of filing of this complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, upon the filing ofAffidavits of Consent to the Divorce by both Plaintiff and Defendant at the expiration of ninety days from the date of the filing of this complaint, or upon a determination that the marriage is irretrievably broken after two years from the Date of Separation, Plaintiff respectively requests this Honorable Court to enter a decree of divorce pursuant to Section 3301(c) or (d) of the Divorce Code accordingly, and to approve any Stipulation reached between the parties with respect to the marital property, or failing such, to equitably divide the same. Res lllly W Date: 444 Gates, Halbruner & Hatch, P.C. Matthew J. Eshelman, Esquire Supreme Court ID No. 72655 1013 Mumma Drive, Suite 100 Lemoyne, PA 17043 (717)-731-9600 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kathleen Y. Furr Plaintiff VS. NO. CIVIL Archie L. Furr Defendant CIVIL ACTION - DIVORCE VERIFICATION I, Kathleen Y. Fun, verify I am the Plaintiff in the foregoing action, and I have read the complaint and it is true and correct to the best of my knowledge, information and belief. I understand that I am subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities for any false statements that I have made in the foregoing complaint. DATED: June 2006 KATHLEEN Y. FURR ? ? ? , a ? ? ? c ? c o i ? ? `,? SHERIFF'S RETURN - REGULAR CASE NO: 2006-04329 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FURR KATHLEEN Y VS FURR ARCHIE L WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon FURR ARCHIE L the DEFENDANT , at 1828:00 HOURS, on the 18th day of August , 2006 at 817 FLINTLOCK RIDGE ROAD MECHANICSBURG, PA 17055 by handing to ARCHIE FURR a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 8.80 Postage .39 Surcharge 10.00 R Thomas Kline .00 37.19,/ 08/21/2006 q M GATES HALBRUNER HATCH / Sworn and Subscibed to By: 7- -- before me this day Deputy Sheriff of A.D. KATHLEEN Y. FURR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-4329 ARCHIE L. FURR, : CIVIL ACTION-LAW Defendant : IN DIVORCE TO THE PROTHONOTARY: PRAECIPE Please withdraw my appearance on behalf of the Plaintiff in the above captioned divorce matter. Date Gates, By Esquire Please enter my appearance on behalf of the Defendant in the above captioned divorce matter. Pur g&H Date Jo W. Purce , Jr. ?- #29955 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 I.D. #72655 1013 Mumma Drive, Suite 100 Lemoyne, PA 17043 (7D, = Curtis R. Long Prothonotary office of the Protbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor _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 0 Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573