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HomeMy WebLinkAbout02-4375JAMIE LYNNE SUMMY, PATRICK M. SULLIVAN, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. -- COMPLAINT IN DIVORCE TO: NOTICE TO DEFEND AND CLAIM RIGHTS Patrick M. Sullivan 159 Ashford Drive Enola, Cumberland County, PA 17025 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. When the ground for 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 Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 1F 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 W~I-IERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Date: By: Andrew C. Spears, Esquire Attorney I.D. No. 87737 3211 North Front Street, P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff JAMIE LYNNE SUMMY, PATRiCK M. SULLIVAN, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW (,~ c,~.]._.qf~ NO. C> --q22S : COMPLAiNT iN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff Jamie Lynne Summy is an adult individual residing at 1215 Minnich Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant Patrick M. Sullivan is an adult individual residing at 159 Ashford Drive, Enola, Cumberland County, Pennsylvania, 17025. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 25, 2002 in Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. Plainti~s Social Security number is 169-70-4655, and Defendant's Social Security number is 166-58-9236. 7. There have been no prior actions of divorce or for annulment between the parties. 10. 11. 12. Defendant. 8. Plaintiffhas been advised that counseling is available, and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. 9. There were no children bom of this marriage. The marriage is irretrievably broken. The parties have been living separate and apart since June 7, 2002. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and WHEREFORE, Plaintiff requests that this Court enter a decree in divorce and any such other orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Date: By: Andrew C. Spears, Esquire Attorney I.D. No. 87737 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff VERIFICATION I, J~i. me Lynne Summy, hereby certify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best o£ my knowledge, information and belie£, and that false statemems herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom £alsification to authorities.