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HomeMy WebLinkAbout06-5468 CV, 1,'S - dtrSon Plaintiff V. nderS o n Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 06- J'YG -F CIVIL TERM 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. When the ground for 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 . . Chi ; s?;Y.9- QrN&rsor, Plaintiff V, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No, O6- S C1 `CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Ck rj T; nsL ), _ A0Lje (-Son, who currently resides at ?)OCAI U . L-lSk . SV. Car,i SL 712 r7G i? Cumberland County, Pennsylvania. 2. Defendant is 7p ° _ 1. c-Zn C -o y, , who currently resides at q 1 cl . C;bSan -V?lv C-1 . Sk4e ? ko" -?a l--? 11-S 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on deb, e') 0" app at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. a. . 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. ? , - - - Z'- , W 15 1 b to Date Plaintiff, Pro Se I,'h,, } , W ,o,-, , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Olo CO Date/ . Plaintiff, Pro Se Assisted by: Hannah Herman-Snyder, Esquire Griffie & Associates 200 N. Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5551 IJ C '; . ,n,cr? ?Sa*1 Plaintiff v. `x a r?u. 3 . -A r-% cl ?S .1 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06- S -q& S' CIVIL TERM DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Christina N. Anderson , Plaintiff, to proceed in forma au eris. I, Hannah Herman-Snyder, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Hannah Herman-Snyder, Esq 'ru'i e Attorney for Plaintiff 200 N. Hanover Street Carlisle, PA 17013 (717) 243-5551 ,._,_! `" _? ? ,. ,,, _.._ - 4r _ C_?, .?1 ?:i ;.? --, j-- ; CHRISTINA N. ANDERSON, Plaintiff V. ZANE J. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO 06-5468 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, on the day of a !A t,}, o r , 2006 comes Hannah Herman-Snyder, Esquire, and states that she mailed a certified and true copy of a Complaint in Divorce and Notice to Defend and Claim Rights to the Defendant, Zane J. Anderson, at his address of 919 Gibson Boulevard, Steelton, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on October 3, 2006. Sworn and subscribed to before me this day of , 2006 rNOTARY P LIC NOTARIAL SEAL ROBIN 1. GOSHORN, NOTARY PUBLIC MY COMMISSIO , XPM EE NE 17U2Op7 (IN-A-A - K %- DNws_n f\ - dm? Aj ,t Hannah Herman-Snyder, Esquiie Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 C U.S. Postal Ser vice,. r-3 ? CERTIFIED MAIL,,, RECEIPT (Domestic Only , Provided) C3 For delivery informna*i n visit our website at www us s com C3 m . p . v M Postage $ k` pp Certified Fee ZI a ?- { C3 p Retum Receipt Fee (Endorsement R i d \ 4 .\ . 3 (! --` v , ( r equ re ) ra 'j J C3 Restricted Delivery Fee r (Endorsement Required) rU Total Postage & Fees $ ul ;. . '.. C3 ? - °-°- -------- -----° -- S tAptNojI/1*1 i•r r, c i A. w ? Items 1, 2• and y 10 de d' is des so #W we can mtt" ? Owd tO you. .e. by a Attach this and to fire baoiuof the ? or an to" if sPWO t' wn ts. D. Is d*MY add%- d&"•"?*M it Dyes A 1. AYWQ bo If YES, anew 4*4&y a ddrsss bdW. D No ??pt,?,1?3bYt P fWO"W 1h fq C% b s 'B6J Pekin ftege" f+artrriMCllet e eAjaAXX la ? C.fJA. D [k*nd MW R•s?cted DNhiwY? ` ?p p f ` P 177113 Z Ar" Nurrdxf 1Mw=Jbrflaens•arlosllo6s91V1 1i?/1 ?.ld?? t5w t?5 FoTn! r`i81 2 C -} Curtis R. Long Prothonotary office of the Protbonotarp Cumberlanb Cuuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 01, - S'g6A 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