HomeMy WebLinkAbout96-02285
I
\
~
I
I
,
!
~ i
I
I
I
!
I
i
J i
I
I
'v,
c.':lo
,...
~
/' /
~:
I '
"
" '
)
/
I
,
v.
I IN THB COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 91. - ,;l...l.S'S C.,;( _7..",,,..-
I
I CIVIL ACTION - LAW
I IN DIVORCE
JBRRY SIMPSON,
Plaintiff
DBVBRLY SIMPSON,
Defendant
COMPLAINT
COUNT I
DIVORCE UNDER BECTION 3301 (C) OR 3301 (D)
OF THE DIVORCE CODE
1. Plaintiff is Jerry Simpson, an adult individual who sui
juris and residee at 1448 High street, Camp Hill, Cumberland
County, Pennsylvania 17011.
2. Defendant ie Beverly Simpson, an adult individual who is
sui juris and resides at 1448 High Street, Camp Hill, Cumberland
County, Pennsylvania 17011.
3. Both Plaintiff and Defendant have been bona fide
residents in the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married in April 1961 in
Winchester, Virginia.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. Plaintiff has been advised of the availability of
couneeling and the right to request that the Court require the
partiee to participate in couneeling.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
VIRIPICATION
Upon my personal knowledge or information and belief, I hereby
verify that the facts averred in the foregoing Complaint are true
and correct to the best of my knowledge, information and belief.
I understand that false statements or averments therein made will
subject me to the criminal penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
DAte I ,/) / '/.(
~ ,'.;.' l.
(\ \~ ~.~
~SIMP N
I verify that I have reviewed this form with my client and to
the best of my knowledge the allegations herein are true and
correct.
l_
~.;.:.. "',
- )
.. ,<~-~-
CARRIE M. BOWMASTER, ESQUIRE
126 Locust Street
P.O. Box 965
Harrisburg, PA 17108-0965
Attorney for Plaintiff
4
f
JERRY SIMPSON, I IN THE COURT OF COMMON PLEAS
Plaintiff I CUMBERlAND COUNTY, PENNSYLVANIA I
I 'II. .;J) J' {('<,,:I 'Ii', ",'
v. I NO. I
I
BEVERLY SIMPSON, I CIVIL ACTION - LAW
Defendant I IN DIVORCE
Al"PIDAVIT
JERRY SIMPSON, being duly sworn according by law, deposee and
eaysl
1. I have been adviBed of the availability of marriage
counseling and underBtand that I may requeet that the Court require
that my Bpouse and I participate in counseling.
2. I underetand that the Court maintain a liet of marriage
counselors in the Prothonotary's Office, which liBt iB available to
me upon requeet.
3. Being eo adviBed, I do not requeBt that the Court require
that my Bpouee and I participate in counBeling prior to a Divorce
Decree being handed down by the Court.
I understand that false statements herein are made subject to
the penalties of 18 Pa. C.S. Section 4909 relating to unsworn
faleification to authorities.
'~-
\)
S'MP N
J
5