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HomeMy WebLinkAbout02-3433Michael R. Waters, Plaintiff Merry C. McDaniel, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A iudgment may also be entered against you for any other cJaim 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 in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMO . LA.W~..E~'S FEES OR EXPENSES a NY..DIVISION OF PROPERTY, GRANTED, YOU MAY LOSE THE RIGHTE~F~)RcEL~MDAI~i(~RoCFETHOERM.ANNULMENT IS YOU SHOULD TAKE THiS PAPER TO YOUR LAWYER AT ONC DO NOT HAVE A LAWYER OR CA _ E. IF YOU THE OFFI NNOT AFFORD ONE, GO TO Miller, Esquire / for Plaintiff CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Istopiffer J. Keller, Esquire Attorney for Plaintiff Michael R. Waters, Plaintiff V. Merry C. McDaniel, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW IN DIVORCE .COMPLAINT IN DIVORC,~ 1. Plaintiff is Michael R. Waters, who currently resides at 217 Winding Way, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Merry C. McDaniel who presently resides at 1075 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 6, 1995, in Cumberland County, Pennsylvania. parties. There have been no prior actions for divorce or annulment between the 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. 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. COUNT 1 RE UEST A R SECTIO. 3304 cl OF THE DIVORCE COD,~ 9. The prior paragraphs of this Complaint are incorporated herein reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. by 11. 12. C~OUNT II EQUITABLE DISTRIBUTIC:.' The prior paragraphs of this Complaint are reference thereto. incorporated herein by The parties have acquired certain property and assets which constitute marital property. 13. In the event the parties are unable to resolve distribution of marital property by way of an agreement, this Honorable Court is authorized to equitably divide, distribute or assign marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree: a) dissolving the marriage between Plaintiff and Defendant; b) equitably distributing all marital property pursuant section 3502 of the Divorce Code. to Respectfully Submitted, Law Office~/~f/~tnes A. Miller BY: ;/~/a-~//~e/~s A' ~Mille r, Esquire _AJ;t~orney for Plaintiff /Z010 Market Street /Camp Hill, PA 17011 J (717) 737 6400 'sto~her J. Keller, Esquire Attorney for Plaintiff 2010 Market Street Camp Hill, PA 17011 (717) 737 6400 Michael R. Waters, Plaintiff Merry C. McDaniel, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : · ' NO. : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. understand that false statements herein are made subject to the penalt es of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: Michael R. Waters, Plaintiff V. Merry C. McDaniel, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3433 CIVIL TERM CIVIL ACTION. LAW IN DIVORCE ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT I, Merry C. McDaniel, Defendant in the above captioned matter do hereby on the date indicated below accept service of the divorce complaint filed by Plaintiff, Michael R. Waters, to the above term and docket.