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HomeMy WebLinkAbout95-07156 " - .~~. ..,'; . ~ jJ ,'" " ~1 r3 !" ~ J , .... ~ l.() - r ','. i. ~r." " ,,-. " , .'!' "i' ,.m<O~:4....~~..~...,:~,.........,....~~", ","_'"._") ',,-" "-:;;:_:'__~":'.' ._ ,>-,.~._-. SHIRLBY L. JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. tJ5- //.5& cw;J~hot IN DIVORCE v. ARLINGTON F. JACKSON, Defendant 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 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 , SHIRLBY L. JACKSON, Plaintiff 1RLINGTON F. JACKSON, Defendant NO. IN DIVORCE COKPLAINT UNDBR SBCTION 3301(C) or TRB DIVORCB CODB 1. Plaintiff is Shirley L, Jackson, an adult individual who currently resides at 149 Faith circle, Carlisle, Cumberland County, Pennsylvania. Plaintiff has resided at this address since 1984. 2. Defendant is Arlington F. Jackson, an adult individual who currently resides at 253 West North Street, Carlisle, Cumberland County, Pennsylvania. Defendant has resided at this address since July of 1994. 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 June 30, 1978 in Steelton, Dauphin 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. 8. Plaintiff avers that the grounds upon which this action . ".' -~ -,. ":-"-'''''+~ ~" ,', . is based are: (A) That the marriage is irretrievably broken (53301(c)); (B) That the parties have lived separate and apart for at least two years and that the marriage is irretrievably broken (53301 (d)), 9. Plaintiff requests that this Court enter a Decree in Divorce. COUNT I - EOUITABLE DISTRIBUTION 10. The allegations contained in Paragraphs 1 through 9, inclusive, are incorporated herein and made a part hereof as if more fully set forth, 11. Plaintiff and Defendant have acquired various items of marital property, including, but not limited to, Defendant's pension, during their marriage from date of marriage to date of final separation. WHEREFORE, Plaintiff requests that this Honorable Court equitably divide all marital property pursuant to the Divorce Code prior to entry of a final divorce decree, Dated: /5.i{u~ 95 nt ff . I Verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.e.S.A. section 4904, relating to unsworn falsification to authorities. By: /67::/ b~ 5- ste~hen B. Lipson, Esquire Attorney for Plaintiff :';,"-" ~i'~':'{; ~:;~:~i:jT;~ . 't": ~J,:r~,'(i;, < ~.- ~,' ., - . . :, '-,- r .',,-' '-"Ii;'.--;. SHIRLEY L. JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 9.5- )g-t, 6tAI~ IN DIVORCE v. ARLINGTON F. JACKSON, Defendant NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 330114) OF THE DIVORCE CODE 1, The parties to this action separated on or about July 1, 1992 and have continued to live separate and apart for a period of at least two years. 2, The marriage is irretrievably broken. 3, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: 1511/:// / ,/ ,/..,j- I" ' .~---lp ,-/ ,.l..' ./<.'1_A jr'/~ _ . /://L(ll' (,r v___-rll ~,!(,... I-~ Shirley L.' ,Jackson, Plaintiff .';-~ ,: ~-' "- . ... . . "--... SHIRLBY L. JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. ARLINGTON F. JACKSON, Defendant NO. 95-7156 CIVIL TERM IN DIVORCE APPXDAVXT OF SERVICE BY CERTIPIED MAIL stephen B. Lipson, Esquire, being duly sworn according to law deposes and says that he is counsel for the Plaintiff, SHIRLEY L. JACKSON, in the above-captioned action. On December 15, 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) and 3301(d) of the Divorce Code in the above- captioned action. Said copy was duly endorsed with a Notice to Defend and Claim Rights. A true and correct copy of Plaintiff's Affidavit under section 330l(d), together with the required Notice to the Defendant, was enclosed in this mailing. Deponent further says that on the 15th day December, 1995, he did receive a receipt for certified article no. Z221285875, and thereafter there was returned by the united states Post Office a return receipt card duly receipted by "ARLINGTON F. JACKSON," the Defendant herein, dated the 18th day of December, 1995. Said return receipt is attached hereto as Plaintiff's Exhibit "A" and made a part hereof, Subscribed and sworn to before me this ;;1/!f!.' day of Vr',,;vrAr,- , 1995 ~""'a""'- ~;;<3:" A_ Notary PUblic .~--4~ st hen B. L pson, Esq. Attorney for Plaintiff 169 W. High st" STE 4 Carlisle, PA 17013 (717) 249-3929 MEN NOTARI~l SEAL c.w.IS~ ~REHIA. NOTARV FU9l1e IIV COIlMISSION . CUMRfRlNlO COU/flV EXPIRES JANUARV 6. 1996 /~I., ,i /i ) . , ,,if ."~J~....'J ~ c ~ c ':) 9 5~ UJ~ C):-.j1 01:"5 -- U~l: lt~ ..0: :::l~ -.J' " ~g ::-~(n N "':l::~ n:-" III C-' Vi ill .,' Ld fi.1o... F 0 ~~"; u. t.n ::J 0 <:Tl U ( ( , ) ( , ) ) ..