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COLLEEN M. SMYSER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
Defendant
CIVIL ACTION - LAW
NO, 1 !,. (1<17 6.'v;..f U-<.._
IN DIVORCE
DANIEL R. SMYSER,
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 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.
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 Court House,
High and Hanover Streets, Carlisle.
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.
Court Administrator, Fourth Floor
Cumberland county Court House
1 Courthouse square
CarliSle, PA 17013
Phone: (717) 240-6200
,
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
COLLEEN M. SMYSER,
Plaintiff
DANIEL R. SMYSER,
Defendant
NO,
IN DIVORCE
COMPLAINT UNDER SECTION 3301(0)
OF THE DIVORCE CODE
1, Plaintiff is Colleen M. Smyser, an adult individual who
currently resides at 329 East Louther street, carlisle,
Cumberland county, Pennsylvania. Plaintiff has resided at said
address since August of 1988,
2, Defendant is Daniel R, Smyser, an adult individual who
currently resides at 182 West Middlesex Drive, CarliSle,
Cumberland county, Pennsylvania, Defendant has resided at said
address since July 7, 1993,
3, Plaintiff and Defendant have been bona fide resident(s)
of the Commonwealth for at least six months immediately previous
to the filing of this Complaint.
4, Plaintiff and Defendant were married on August 13, 1988
in CarliSle, Cumberland county, Pennsylvania.
5, There have been no prior actions for divorce or
annulment between the parties hereto in this or any other
jurisdiction,
6. The marriage is irretrievably broken.
7. Plaintiff avers that she has been advised of the
availability of counseling, and that she may have the right to
request that the Court require the parties to participate in
counseling.
..-
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
COLLEEN M. SMYSER,
v,
Defendant
NO, 95-949 CIVIL TERM
IN DIVORCE
DANIEL R. SMYSER,
AFFIDAVIT OF SERVICE
BY CERTIFIED MAIL
Stephen B. Lipson, Esquire, being duly sworn according to
law deposes and says that he is counsel for the Plaintiff,
COLLEEN M. SMYSER, in the above-captioned action. On February
23, 1995 he did deliver for mailing at the United States Post
Office in carlisle, Pennsylvania as certified mail, restricted
delivery a true and correct copy of Plaintiff's complaint under
section 3301(C) of the Divorce Code in the above-captioned
action, Said copy was duly endorsed with a Notice to Defend and
Claim Rights.
Deponent further says that on the 23rd day February 1995, he
did receive a receipt for certified article no. Z069B70B31, and
thereafter there was returned by the United States Post Office a
return receipt card duly receipted by "DANIEL R. SMYSER", the
Defendant herein, dated the 25th day of February 1995, Said
return receipt is attached hereto as Plaintiff's Exhibit "A" and
made a part hereof,
7'7 - O;J
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. Staphen B. L pson, Esqui~e
Attorney for Plaintiff
169 W. High st. Ste. 4
Carlisle, PA 17013
(717) 249-3929
Subscribed and sworn to before me
this 1~7 dl.Y of /,/,;.ul1 , 1995
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Notary public
1j(1l~~14L SEAL
IlllUlO^ L OnlHM. NOTARY ruOLlC
CARLISlf IlORO. r.UlIBEnLAHO CDUlHY
lIY COMMISSION U\I'lRlS JANUARY O. 1M
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