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Home My WebLink About02-3160DENNIS E. MEYER, JR., Plaintiff JANET M. MEYER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : IN DIVORCE :NO. 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, 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 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any heating or business before the court. You must attend the scheduled conference or hearing. DENNIS E. MEYER, JR., Plaintiff JANET M. MEYER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : IN DIVORCE : : NO. 02 - 3160 CIVIL TERM PROOF OF SERVICE Understanding that the making of any false statement would subject her to the penalties of 18 Pa. C.S. §4904 (relating to unsworn falsification to authorities), the undersigned verifies that the Family Law Clinic served a true copy of the Divorce Complaint on the Defendant by placing the same in the U.S. Mail, certified no. 7001 2510 0003 4482 1822, restricted delivery, return receipt requested, postage prepaid, on the 5t~ day of July, 2002, addressed as follows: Janet Meyer, 832 Factory Street, Carlisle, PA 17013. On or about the llth day of July, 2002, return receipt no.7001 2510 0003 4482 1822 was delivered to the Family Law Clinic, bearing the signature of Janet Meyer and showing a date of service of July 9, 2002. The sender's receipt and return receipt are attached hereto and incorporated by reference. Date ' Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243 -2968 OFFIC~AL Certified Fee Restricted Delivery Fee "b~, s~e, z/P+~ U S~ 2510 Domestic Return Receipt PS Form 3811, August 200;I ~" FRANCES J. AusTiN, ,.~ ~ Plaintiff I~IO L ' A~)Te fe~r~dant iN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW iN DIVORCE NO. 02 - 3195 CIVIL TERM ".. ~CERTIFICATE O~'/~ERVICE i Jennifer . , "'"'"~'~'~., _~ , r~everiy, cert~/~,g~l Intern, Family Law Clinic, hereby certify that I am serving a true and correct co~'l~h~ached Proof of Service this date on Defendant, David Austin of 32 H Street, C?~le, Pennsylv"a~, 17013, by depositing a copy of the same in the United States mail,,F~Class, postage prepaid. Date Jennife/Heverly Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 :.,-: '.. [ CERTIFICATE OF SERVICE I, Jennifer Heverly, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the attached Proof of Service this date on Defendant, Janet Meyer of 832 Factory Street, Carlisle, Pennsylvania, 17013, by depositing a copy of the same in the United States mail, First Class, postage prepaid. Date Jennif~ Heverl~ Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 DENNIS E. MEYER, JR., Plaintiff JANET M. MEYER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN DIVORCE NO. ~)o~- DIVORCE COMPLAINT The plaintiff, Dennis E. Meyer, Jr., by his attorneys, the Family Law Clinic, sets foFth the following cause of action in divorce: COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Dennis E. Meyer, Jr., who currently resides at 7073 Carlisle Pike, Lot # 132, Carlisle, Cumberland County, Pennsylvania, 17013 since July of 1999. 2. Defendant is Janet M. Meyer, who currently resides at 832 Factory Street, Carlisle, Cumberland County, Pennsylvania, 17013 since approximately March of 2002. 3. The plaintiff and the defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on December 4, 1999 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since November 11,2001. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. WHEREFORE, plaintiff requests the coust to enter a decree of divorce. Date Respectfully submitted, Jennife~rl~ ' Certified Legal Intern ROBERTE. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968 VERIFICATION I verify that the statements made in this Complaint are tree 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. Dennis E. Meyer, Jr., Plaintiff DENNIS E. MEYER, JR., Plaintiff JANET M. MEYER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : IN DIVORCE : NO, ~>~_. _'~1~ o C :~t, I -f~ ~'-n... PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Dennis E Meyer, Jr., Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma paupefis, certifies pursuant to Pa. R.C.P. No. 240(d) that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Respectfully submitted, Jennifo[ ~everly ~ Certified Legal Intern ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968 VERIFICATION 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. Dennis E. Meyer, Jr., Plmntiff F~ DENNIS E. MEYER, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : IN DIVORCE : JANET M. MEYER, : NO. ~5~.. ~'~ I ~ o Defendant : PRAECIPE TO PROCEED IN FORMA PAUPER. IS To the Prothonotary: Kindly allow Dennis E. Meyer, Jr., Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies pursuant to Pa. R.C.P. No. 240(d) that we believe the patty is unable to pay the costs and that we are providing free legal service to the party. Date Respectfully submitted, J nni f Certified Legal Intern ROBERT E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968