HomeMy WebLinkAbout00-00890
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HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
35 EAST HIGH STREET
CARLISLE PA 17013
(717) 243.6090
ATTORNEY FOR PLAINTIFF
KEITH L. VANASDLE;N,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 00 - ~O CIVIL TERM
VICKI A. VANASDLEN,
Defendant
: IN DIVORCE
NOTICE
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 in 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,
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, Cumberland County Courthouse, Carlisle,
Pennsylvania 17013.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
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KEITH L. VANASDLEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
: CIVIL ACTION. LAW
: NO. 00 - O'C1o CIVIL TERM
VICKI A. VANASDLEN,
Defendant
:
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION
3301~ OF THE DIVORCE CODE
NOW, comes the plaintiff, by his attorney, Harold S, Irwin, III, Esquire, and files
this complaint in divorce against the defendant, representing as follows:
1, The plaintiff is Keith L. Vanasdlen, an adult individual residing at 11 Hill
Road, Carlisle, Cumberland County, Pennsylvania 17013,
2, The defendant is Vicki A. Vanasdlen, an adult individual residing at 32
North Baltimore Avenue, Apartment 2, Mt. Holly Springs, Cumberland County,
Pennsylvania 17065,
3, The parties have been residents of the Commonwealth of Pennsylvania at
least six months prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married on July 13, 1998, in Carlisle,
Pennsylvania,
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5, Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the
grounds upon which this action is based that the marriage between the parties is
irretrievably broken,
6. The plaintiff avers that he has been advised of the availability of
counseling and that he has the right to request that the court require the parties to
participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between
the two parties,
I verify that the facts contained herein are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa, C, S. Section 4904
relating to unsworn falsification to authorities,
February 10,2000
~~
KEITH L. VANASOLEN, Plaintiff
35 East High Street
Carlisle, Pennsylvania 17013
(717) 243-6090
Supreme Court 10 No. 29920
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KEITH L. VANASDLEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION. LAW
: NO. 00 .890 CIVIL TERM
VICKI A. VANASDLEN,
Defendant
: IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1, I have been advised of the availability of marriage counseling and
understand that I may request that the court require that my spouse and I participate in
counseling,
2, I understand that the court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3, Being so advised, I do not request that the court require that my spouse
and I participate in counseling prior to a divorce decree being handed down,
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, Section 4904 relating to unsworn falsification to authorities,
February 10, 2000 fP~
KE~'/L~ ANASDLEN, Plaintiff
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KEITH L. VANASDLEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 2000 - 0890 CIVIL TERM
VICKI A. VANASDLEN,
Defendant
: IN DIVORCE
ACCEPTANCE OF SERVICE
I, Vicki A, Vanasdlen, defendant in this divorce action, hereby certify that I
received a copy of the complaint in divorce on February 21, 2000, by personal service
at the office of Harold S, Irwin, III, Esquire,
I verify that the statements made in this acceptance of service are true and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities,
February 21, 2000
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VICKI A. V ANASDLEN
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