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ROSBMARY L. SLBBODA,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF'
CUMBERLAND COUNTY, PENNSYLVANIA
No. -if... . i'llte, ri"','l C
CIVIL ACTION - AT LAW
IN DIVORCE
GBORGB S. SLBBODA,
Defendant
NOTICB TO DBFEND AND CLAIH RIGll'rS
You have been sued in court. If you wish to defend against
the olaims set forth in the following pages, YOll mUBt tske prompt
aotion. You are warned that if you fail to do so, the oase may
prcceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may aleo be entered
against you for any other claim or relief reqllested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
ohildren.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling.
A list of marriage cOllnselors is available in the
Office of the Prothonotary at the Cllmberland COllnty Courthouse,
Carlisle, Pennsylvania
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 LIIWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THB
OFFICB SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HBLP.
couln ^DM1NISTHNJ'OH
CUMllEHI.^NIJ CO COl! I<TIIOl!SE 4t: h FI.OCm
1 COlJl<'I'HOlJSE SQlJ^IH:
CMlLISI.E P^ 17013 33B7
(717) 240 6200
,
ROSEMARY L. SLBllODA,
Plaintiff
VS.
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
: No. 'J!.. .1',"1(. C~~...(r;.."
I
I CIVIL hCTION - AT LAW
I IN DIVORCE
GBORGB S. SLBBODA,
Defendant
COMPLAINT IN DIVORCE
The Plaintiff, Rosemary L. Sleboda, through her attorneys,
the Law Offices of Patrick F. Lauer, Jr., makes the following
Complaint in Divorcer
1. The Plaintiff, Rosemary L. Sleboda, is an adult
individual who currently resides at 5 Donald Street,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant, George S. Sleboda, is an adult
individual who currently resides at 5 Donald Street,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. The Plaintiff and the Defendant have been residents of
the Commonwealth of Pennsylvania for at least six months
immediately prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on January
28, 1967 in Scranton, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised that counseling is
available and that the Plaintiff may have the right to request
that the oourt require the partifls to participate in counseling.
8. The Plaintiff requests the Court to enter a deoree in
divoroe.
COUNT II - EQUITABLE DISTRIBUTION
9. Paragraphs one (1) through eight (8) are inoorporated
herein by reference thereto.
10. The Plaintiff requests Your Honorable Court to
equitably divide, distribute, or assign the marital property
between the part.ies without regard to marital misoonduot in such
proportion as the Court deems just after consideration of all
relevant factors.
WHEREFORE, the Pl.a3.ntiff requests this Court to enter a
deoree of Divorce in this matter.
WHEREFORE, the Plaintiff respectfully requests the Court to
enter an Order of Equitable Distribution of marital property
pursuant to 23 Pa. C.B.A. 3502 (c) of the Divorce Code.
RiiW,"ll~ittt.d'
Matthew J Eshelman, Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID~ 72655 Tel. (717) 763-1800
b ~ Ie
Datel
ROSBMI\RY L. SLBBODA, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
VS. I No.
I
GBORGB S. SLBBODA, I CIVIL ACTION - AT LAW
Defendant I IN DIVORCE
VERIFICATION
I, Rosemary L. Sleboda, state that I am the Plaintiff in the
above-oaptioned oase and that the faots set forth in the above
Complaint are true and oorrect to the best of my knowledge,
information, and belief. I realize that false statements herein
are subject to the penalties fot' unsworn falsification to
authorities under 18 Pa. C.S. S 4940.
!i
,- ("
t'ti ;!.J(..O-/L' v . >4-.(,;)0",;.
Rosemary L. leboda
I
,
,
Ii
Datel
l,-(~J.,. 9/-,
.
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