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HomeMy WebLinkAbout02-4390WILFREDO E. TAYLOR, Plaintiff VS. CHRISTINE D. TAYLOR, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 0.2. q3 qo Civil Term : :ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3166 WILFREDO E. TAYLOR, Plaintiff VS. CHRISTINE D. TAYLOR, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0.2- t/39t) Civil Term :ACTION IN DIVORCE C~OMPLAINT UNDER SECTION 3301 of the DIVORCE CODy; 1. Plaintiffis Wilfrcdo E. Taylor, who currently resides at 352 A Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Christine D. Taylor, who currently resides at 352 A Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 13, 1992, in Chambersburg, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff and Defendant have one child together. 9. Neither Plaintiff or Defendant are a member of the military. 10. The Plaintiffavers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiffrequests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. · fred4~E. Taylo~e~l~intiff Respectfully submitted: ~6eEe~quir~ Carlisle, Pa. 17013 ATTORNEY FOR PLAINTIFF WILFREDO E. TAYLOR, Plaintiff VS. CHRISTINE D. TAYLOR, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ::No.O~ - /~]~ O[(_~ Civil Term :ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT AND NOW, this September 23, 2002, I, Jane Adams, Esquire, hereby certify that on September 17, 2002, a certified true copy of the NOTICE TO DEFEND AND was served, via certified mail, restricted delivery, return receipt requested, addressed to: Christine Taylor Mobile Xray Imaging 5120 Lancaster Street Harrisburg, Pa. 17111 DEFENDANT pectfully Submitted: ( 36~South Pitt~.ee_t x--~arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~2, ~ Numbe~ ~S Form 3811, August 2001 is deliveW edd~eSS ti YES, enter delNe~Y addreSs below: f'l Yes 0 No DomeStiC Return Receipt · Sender: Please print YOur name, address, and ZIP+4 in this box · ~6'~OI:INEY AT LAW $. PITT STREET