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RICHARD E. STOUGHTON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO 95- 7/:;},
CIVIL TERM
TRISHA C, STOUGHTON,
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 divorce is indignities or irretrievable
breakdown of the marriage, you may request that the court require
you and your spouse to attend marriage counseling prior to a
divorce decree being handed down by the court. A list of
marriage counselors is available in the Office of the
Pro~honotary at the Cumberland county Court House, Carlisle. 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 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 WHERE YOU CAN GET LEGAL HELP.
LAW O""IClEa
SNEL8AKER
a
BRENNEMAN
Court Administrator
One Courthouse Square
carlisle, Pennsylvania 17013-3387
(717) 240-6285
'NEL',!", '~ENNE"'" P.C.
By UfJ.)neYS~tiff
LAW O"ICI:.
SNELSAKER
..
BRENNEMAN
RICHARD E. STOUGHTON, . IN THE COURT OF COMMON PLEAS OF
.
plaintiff , CUMBERLAND COUNTY, PENNSYLVANIA
,
vs. : NO 95- CIVIL TERM
.
,
TRISHA C. STOUGHTON, .
.
Defendant . IN DIVORCE
.
COMPLAINT
1.
The Plaintiff in this action is RICHARD E, STOUGHTON, an
adult individual, who resides at 36 Sunset Drive, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
2.
The Defendant in this action is TRISKA C. STOUGHTON, an
adult individual, who resides at 1201 Highland Drive,
Mechanicsburg, cumberland county, pennsylvania 17055.
3.
Both parties have been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of this complaint.
4.
The Plaintiff and Defendant were lawfully joined in marriage
on April 12, 1986, in Middlesex Township, Cumberland County,
Pennsylvania.
5.
There have been no prior actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction
since the date of the marriage averred in Paragraph 4 above.
6.
Neither party is a member of the armed forces of the United
states of America.
7.
The Plaintiff avers as the grounds upon which this action is
based is that the marriage between the parties hereto is
irretrievably broken.
8,
The 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.
9.
The Plaintiff requests the court to enter a decree of
divorce.
WHEREFORE, Plaintiff, RICHARD E. STOUGHTON, prays your
Honorable Court to enter a decree of divorce, divorcing the
Plaintiff from the bonds of matrimony heretofore existing between
LAW O'''c:ca
SNELDAKER
a
BRENNEMAN
-2-
the Plaintiff and the Defendant.
Date: February 6, 1995
SNELBAKER & BRENNEMAN, P.C,
By' I{fk~
--~h O. Brenneman
Attorney for Plaintiff
44 West Main street
Mechanicsburg, PA 17055-0318
(717) 697-8528
Attorneys for Plaintiff
LAW o,,'c..
SNELDAKER
a
BRENNEMAN
-3-
VERIFICATION
I verify that the statements made in the foregoing Complaint
are true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. S 4904 relating
to unsworn falsification to authorities.
Lt'.
chard E. S ughton
Plaintiff
. //
-_.z:::
Date: February 6, 1995
LAW o,,.ClEe
SNELDAKER
a
BRENNEMAN
LAW O",.ClE8
SNELDAKER
a
BRENNEMAN
RICHARD E. STOUGHTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
,
vs. NO 95-712 CIVIL TERM
TRISHA C. STOUGHTON,
Defendant . IN DIVORCE
.
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
.
.
SS,
COUNTY
OF
CUMBERLAND)
Keith o. Brenneman, Esquire, being duly sworn according
to law deposes and says: that he is a principal in the law firm
of Snelbaker & Brenneman, P. c., being the attorneys for Richard
A. Stoughton, the Plaintiff in the above captioned action in
divorce; that on February 14, 1995, he did send to Defendant
Trisha C. Stoughton by certified mail, return receipt requested,
restricted delivery, a duly certified copy of the Complaint in
Divorce which was filed in the above captioned action as
evidenced by the attached cover letter of the same date and
Receipt for Certified Mail No. Z 115 697 270; that both the
Complaint and cover letter were duly received by Trisha C.
Stoughton, the Defendant herein, as evidenced by the return
receipt card for said certified mail dated February 21, 1995;
that a copy of the aforementioned cover letter dated February 14,
1995 is attached hereto and incorporated by reference herein as
"Exhibit A" and that the original Receipt for Certified Mail and
.....
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