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HomeMy WebLinkAbout06-4736 NICOLE L. DURAND, Plaintiff VS. MARIO S. DURAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. (Z - Y73(o Civil Term ACTION 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 NICOLE L. DURAND, Plaintiff VS. MARIO S. DURAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.OL-k73(o Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Nicole L. Durand, a competent adult individual, who has resided at 643 Heritage Court, Mechanicsburg, Cumberland Country, Pennsylvania, since 7/28/06. 2. Defendant is Mario S. Durand, a competlent adult individual, who resides at 326 N.W. 101 Terrace Coral Springs, Florida, 33071. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were mahied on November 20, 1991 in Fort Lauderdale, Florida. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have one child together, namely, Samantha Olga Durand, date of birth, February 22, 1991. 8. Plaintiff is a citizen of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, 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 unworn falsification to authorities. C G Nicole L. Duran P ainti Respectfully submitted, Date: ('a _ I Y! D.JNo. 79465 outh Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 1 on c; r ?? L IN NICOLE L. DURAND, Plaintiff vs. MARIO S. DURAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. UG _L4r1%Jb Civil Term ACTION IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated in 1994 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Dater -??. ? ?? ?? ?' ? ?-C,:?. , r L.' ? .f?- T_ ?? G ? C,J1 ....? Curtis R. Long Prothonotary Office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Qb -q73L 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