HomeMy WebLinkAbout95-02498
MILTON H. DAVIS,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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( I 1'1 ( _ I I II
vs.
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NO. . " r, 0
TIlERESA M. DAVIS,
Defendant
CIVIL ACTION - LAW
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 dscree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
againet you for any other claim or relief requeeted in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, inoluding custody or visi tation of your ohildren.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request mar'riage
counseling. A list of marriage counselors is available at the
Office of the Prothonotary.
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 TilE RlGllT TO CLAIM ANY OF TIlEM.
YOU SHOULD TAKE TillS 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
IlELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY COURTIlOUSE
Carlisle, Ponnsylvania 17013
(717) 240-6200
THERESA M. DAVIS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 'h',;J 'f'th' (',...1 7;,..,
MILTON H. DAVIS,
Plaintiff
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AND NOW comes the Plaintiff. Milton Il. Davis, by and through
his attorney, Charles Rector, Esquire, of Costopoulos, Foster &
Fields, and respectfully repreBentB as followsl
1. Plaintiff ie Milton Il. Davie. who currently resides at 3
Care Street, Ilarrillburg, Dauphin County, Penneylvania, 17109.
2. Defendant ie Therasa M. Davie, who currently resides at
107 Slover Road, Mechaniollburg, Cumberland County, Pennsylvania,
17055.
3. Plaintiff and Defendant have been bona fide rssidents of
the Commonwealth of Pennsylvania for a period of eix (6 I months
immediately preceding the filing of this Complaint.
4. Plaintiff and Defendant were married on May 7, 1960, in
Clearf1eld County, I'ennsylvania.
5. There have been no prior actione of divorce or for
annulment between the partieB.
6. "he Plaintiff and lJefendnnt are hoth citizens of the
United StateR of Amorica.
COUNT _L::..->>ll'OJikl
7. The allegations of Paragraphs 1 through 6 are
inoorporated herein by reference and made a part hereof.
a. This action is not brought through collusion between the
Plaintiff and Defendant, but in eincerity and truth for the reaeons
set forth within.
9. The marriage is irretrievably broken, and the Parties are
proceeding under Section 3301(0) of the Divorce Code.
10. Plaintiff has been advised that counseling is available
and that Plaintiff may have the right to request that the Court
require the parties to partioipato in counsoling.
COUNT II
IQUlTA8Ll-DlITftlBU7I2B
11. Paragraphs One through Ten of this Complaint are
inoorporated herein by reference as if set forth at length.
12. The parties have acquired, during the courB. of the
mar'riage and prior to separation, property, both real and personal.
which they own jointly or' which was otherwi BS purcha8sd BO a8 to
constitute marital property wHhln the definition and soope of
SsoUon 3502 of the OivOl'ce Code.
WHEREFORE, the Plaintiff, Milton H. Davis, respectfully
requests Your Honorable Court to enter a decree dissolving the
marriage between the Plaintiff and Defendant and to enter an Order
dietributing the marital property, and for such other relief as the
Court may deem equitable and just.
Respectfully submitted,
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Datedl
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Charles R ctor, Esquire
COSTOPOULOS, FOSTER & FIELDS
831 Market Street, P.O. Box 222
Lemoyne, Pennsylvania 17043
Phone I (717) 761-2121
Attorney for Plaintiff
I verify that the statemente msde in this Complaint are true
and correct. I understand that false statemente herein ere made
subject to the penaltieB of Ie Pa.C.S. Section 4904, relating to
unsworn falBification to authoritieB.
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Mil ton II.
.,V
Davie
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