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THOMAS G. BLAffi,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs
CIVIL ACTION - LAW
NUMBER: O()-~/q'l CIVILTERM
DONNA L. BLAffi,
IN DIVORCE
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 including custody or visitation of your children.
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 the Cumberland County Courthouse, One South Hanover Street, 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 LffiERTY AVENUE
CARLISLE PA 17013
(717) 249 - 3166
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Sally J. inde;., Esquire
Attorney for Plaintiff, THOMAS G. BLAIR
701 East King Street
Shippensburg PA 17257
(717) 532 - 9476
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THOMAS G. BLAIR,
IN THE COURT OF COMMON PLF,AS OF
CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff
vs
CIVIL ACTION - LAW
NUMBER: ()-D- i/../'t'l
CIVIL TERM
DONNA L. BLAIR,
IN DIVORCE
Defendant
COMPLAINT IN DIVORCE
COMES NOW, the Plaintiff, THOMAS G. BLAIR, by and through his counsel, SaUy J.
Winder, Esquire, and represents as follows:
1. Plaintiff is THOMAS G. BLAIR, who currently resides at, and whose mailing address
is, 223 Southside Drive, Newville, Cumberland County, Pennsylvania, since December 1984.
2. Defendant is DONNA L. BLAIR, who currently resides at, and whose mailing address
is, 223 Southside Drive, Newville, Cumberland County, Pennsylvania, since December 1984.
3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 30, 1983 at Shippensburg, Cumberland
County, Pennsylvania,
5, There have been no prior actions of divorce or for annulment between the parties,
6. The marriage is irretrievably broken.
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7. Plaintiff avers that he has been advised of the availability of counseling sessions for both
parties upon request of either party or by order of court, and that a list of qualified professionals
who provide such counseling service is available at the Domestic Relations Office upon request.
By the filing of this Complaint, the Plaintiff acknowledges having been advised by his attorney of
record of the availability of counseling sessions and of a list of qualified professionals, Plaintiff
further avers that he has been advised that the choice of a qualified professional shall be at the
option of the Plaintiff and Defendant and need not be selected from the list available upon request
and, further, that arrangements for and the payment of the services of the qualified professional
shall be the responsibility of the parties and will not be included in the docket costs of this
proceeding.
8, Plaintiff requests the Court to enter a decree of divorce.
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Attorney for Plaintiff, THOMAS G. BLAIR
701 East King Street
Shippensburg PA 17257
(717) 532 - 9476
Date:
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VERIFICATION
I veritY that the statements made in this complaint are true and correct to the best of my
personal knowledge and belief 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.
Date: I.f Id~
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THOMAS G. BLAIR
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In the Court of Common Pleas of
Cumherland County, Pennsylvania
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