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Home My WebLink About06-6273. W 06 FAUser FolderTirm Docs\Gendocs2006\4024-1div.compWnt.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CUNNY D. LOVE, Plaintiff CIVIL ACTION - LAW/? V. No. 2006- 4.Z.`.3 0, ! JENNIFER LOVE, 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 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CUNNY D. LOVE, Plaintiff V. CIVIL ACTION - LAW No. 2006- JENNIFER LOVE, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this Z-5f" day of &,"ev" , 2006 comes Plaintiff, Cunny D. Love, by and through his attorneys, Knight & Associates, P.C., and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Cunny D. Love, who resides at 400 G Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant is Jennifer Love, who resides at 3804 Gloucester Drive, Hopewell, Virginia 23860. 3. The Plaintiff and Defendant are sui juris, and Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on July 23, 1993, in Korea. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Section 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. 6. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, HT & ASSOCIATES, P.C. Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint in Divorce 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 of my 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 unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. C ove 6- uz .fA c G C? ?'? -rt CSC ?- FAUserFolder\Firm Docs\Gendocs2006\4024-lcert.servioe.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CUNNY D. LOVE, Plaintiff V. CIVIL ACTION - LAW No. 2006-6273 JENNIFER LOVE, Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this Zls`? day ofNovember, 2006, I, SeanM. Shultz, Esquire, hereby certify that the following person was served with a True and Correct copy of the Complaint in Divorce filed in the above-referenced matter. The Complaint was mailed on October 30, 2006, but actual service took place on November 2, 2006, by Defendant signing for a copy of the Complaint in Divorce which was mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Jennifer Love 3804 Gloucester Drive Hopewell, Virginia 23860 A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, KNIGHT & ASSOCIATES, P.C. J_e? - Sean M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive., Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 FAUwFolder\FirmDocs\Gendocs2006\4024-]cert.savice.wpd Attorneys for Plaintiff ru rl I" cc C r N IA L N cc E Ir U m E S 8 0 N 2 .C m LL T T co M 0 U- M n r'? ?'`S r?+? --f ?~ i????µ ? ` ???... -.-. - ` C i _- .?-. .? `..: Curtis R. Long Prothonotary office of the Protbonotarp Cumberlarlb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor -L 4' 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