HomeMy WebLinkAbout94-04127
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CATHERINE M. SALVADOR, I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
plaintiff I
v. I NO. 94-4127 CIVIL TERM
I CIVIL ACTION - LAW
TODD A. PERRY, I
I IN DIVORCE
Defendant I
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY I
Kindly withdraw and discontinue the above referenced action
with prejudice.
Respectfully Submitted,
DeArmond & DeArmond
~/ ~
By:/ . .~'7!B, . >1-... ,
e th B; eArmo~Esquire
Attorney for Plaintiff
supreme Court 10 No. 58878
2800 Market street
camp Hill, PA 17011
(717) 730-9394
Date:~l1s
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LAW O,."ICI:S
SN&:LI]AI<E.R
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BAIl'.NNEMAN
CATHERINE SALVADOR, I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff I
v. I
I NO. 94-4127 CIVIL TERM
TODD A. PERRY, I CIVIL ACTION - LAW
Defendant IN DIVORCE
DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT IN DIVORCE
1. Admitted. By way of further answer, it is averred that
Todd A. Perry is the sole owner of the house in which Plaintiff
is residing. Todd A. Perry has filed an Ejectment Action
docketed to No. 94-5787 in this Court seeking possession of 1520
High Meadow Lane, Mechanicsburg (Lower Allen Township),
Cumberland County, Pennsylvania.
2. Admitted.
3. Admitted.
4. Denied. It is denied that Plaintiff and Defendant
entered into a common law marriage on or about August of 1984.
On the contrary, it is averred that Plaintiff and Defendant never
married.
5. Denied. It is denied that the parties separated on or
about August of 1991. On the contrary, it is averred that
Plaintiff and Defendant have never been married to each other and
therefore, could not have "separated". By way of further answer,
it is averred that the parties were intermittent romantic
partners and resided together intermittently from in or about
August of 1984 until in or about August of 1991, but were never
married to each other.
6. Admitted in part Rnd denied in part. It is admitted
that neither party has instituted any prior action of divorce or
annulment in this or any other jurisdiction. It is denied that
there was ever a marriage between the parties. On the contrary,
it is averred that the parties were never married to each other.
7. Admitted in part and denied in part. It is denied that
there are two children by the marriage. On the contrary, it is
averred that Plaintiff and Defendant have never been married to
each other and therefore, could not have produced children "by
this marriage." It is admitted that Plaintiff is the mother of
Leah Salvador, born February 1, 1986 and Gabrielle Salvador, born
July 25, 1989. After reasonable investigation, Defendant is
without knowledge or information sufficient to form a belief as
to the truth of the implied averment that he is the father of the
two childr~n named hereinabove.
By way of further answer, it is averred that Defendant
declined to acknowledge paternity of the two children in the
child support case initiated by Plaintiff against Defendant
docketed at No. 847 Support 1994, Domestic Relations Section,
I.I\W OI"I'ICIr$
SNEI..BAKER
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BAIENNI[MAN
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