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HomeMy WebLinkAbout94-07187 !:> 7<)r~.-.;. '. ,'f "Z;:t:~t(f'\,' , )?:t;\;f;';~;:,. ,< ,,~,":<:':';-,',:,:; ..' ':. .' .... ~~,.Y..:':.' .:". c. .' , ;JAlII!S 1lI;'8ACIi,.,' ,.'c,. ":. , . ',', . '''I~''E'fMDCOUNIi!~AT''', . ,,'. 8IiIalnhw""'latlHlU.RQAD . : '.'IIECH.~PlHNAt" ,.' <'..".~..~ - -.'F";.: NATALIE J. NICKEY IN THE COURT OF COMMON PLEAS PLAINTIFF . CUMBERLAND COUNTY, PENNSYLVANIA . vs. . C/I./-l /<87 c:uJ ~CIVIL ACTION . EDWARD A. NICKEY . . 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 in divorce or annulment may be entered against you by the Court. A judgement may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or visitation of your children. When the groundS for divorce are 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, on the first floor of the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES, OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGH'f TO CLAIM ANY OF THESE. 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 BELON TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administration Fourth Floor Cumberland County Court House Carlisle, PA 17013 717-240-6200 , NATALIE J. NICKEY . IN THE COURT OF COMMON PLEAS . PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . 94 - CIVIL ACTION . . . EDWARD A. NICKEY DEPENDANT IN DIVORCE COMPLAINT IN DIVORCE COUNT I AND NOW comes the Plaintiff, by Attorney JAMES M. BACH, and avers as follows: 1. Plaintiff is NATALIE J. NICKEY currently resides at 1071 HARRISBURG PIKE, CARLISLE, , who PA 17013 2. Defendant is EDWARD A. NICKEY , who currently resides ut 214 R SUMMER LANE, ENOLA, PA 17023 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were marri~d on 6/6/83 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and also the Plaintiff may have the right to request that the Court require the parties to participate in counseling, and after being so advised, Plaintiff does not desire counseling. \: ".- .. "'01'" REY 110 COfotUONWlAl.TH(l' I"tNHSYllllHlA 0IN.A1WfNt 0# HlAlI" VITAL "'COftOl CUMBERLAND DIVORCE [8] RECORD OF OR ANNULMENT (CHECK ONE) 0 BTATE FILE NUMBER COUNTY STAT! FILE DATE HUSBAND NICKEY (l"'1 2 DATE OF BIRTH St.,. <t, PlACE OF BIRTH 7. USUAL OCCUPATION (Month) (0.." 10 31 ,..., EDWARD (F,rsf) A ("'~I I. NAME 62 3. RESIDENCE SI""'OtRD C/f)(Bot'o.otl'wp County (SI,t. Of F~ CtxltltrtJ PENNSYLVANIA " NUMBER OF THIS ..ARRIAGE . RACE WHITE BLACK OTHER ISI*I'Y1 1 !Xl 0 0 WIFE (FIfI'} ("'~J NATALIE J. StrHf or R D CIf)I 80tD 01 l'Irp COtJnty II RACE 1 WHITE BLACK OTHER (Specify) Dc 0 0 UNEMPLOYED eo MAIDEN NAME (lat} . DATE (Monlll) {D..,} ,", OF NICKEY BIRTH 11 15 65 sr... ". PlACE (Sr.,. Ot FtniQII Coon'ry) OF PENNSYLVANIA BIRTH 14. USUAL OCCUPATION 10. RESIDENCE 12 HUMBER OF THIS MARRIAGE CUSTOMER RELATIONS MANAGER 20. NUMSER OF CHILDREN 10 CUS100V Of HUSBAND o WIFE ~ SPLIT CUSTODY o OTHER ISpeclfyl ,.. DATE OF iMon'''} (Do,) ~I THIS 6 6 83 MARRIAGE ... DECREE GRANTED TO HUSBAND WIFE OTHER ISptClfyl 0 !ill 0 " LEGAL GROUNDS FOR DIVORCE OR ANNULMENT NO-FAULT DATE REPORT SENT (AIOtItIl) (o.}') ,- TO VITAL RECORDS us. PlACE OF (County) THIS MARRIAGE '7". NUMBER Of CHILDREN THIS MARRIAGE 2 tSt.,. IN FtWfQfI Country) BALTIMORE MARYLAND 178 NUMBER OF DEPENDENT 11, PLAINTIFF CHILDREN UNDER II HUSBAND WIFE 2 0 Q 22 DATE OF DECREE (AIon''') tD4}'J ,- 24. SIQNATURE OF TRANSCRIBING CLERK , \. .. .. ~ ~