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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CATHERINE J. WALTERS,
Plaintiff
CNIL ACTION -LAW
v. No. 2007- ~Z~ ~ ~ ~ v ~ ~~~--~
NORMAN E. WALTERS, .
Defendant IN DNORCE
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 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 the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available at the Domestic
Relations Office, l3 North Hanover Street, Cazlisle, Pennsylvania. You are advised that this list is
kept as a convenience to you and you aze not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within twenty (20)
days of the date on which you receive this notice. Failure to do so will constitute a waiver of your
right to request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TffiS 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 Baz Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CATHERINE J. WALTERS, .
Plaintiff
CIVIL ACTION -LAW
No. 2007- /~~~
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v.
NORMAN E. WALTERS, .
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, this J! day of March, 2007 comes Plaintiff, Catherine J. Walters, by and
through her attorneys, Knight & Associates, P.C., and files the following Complaint in Divorce, and
in support thereof avers as follows:
1. The Plaintiff is Catherine J. Walters, who resides at 174 Stonehedge Lane,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant is Norman E. Walters, who resides at 130 W. Ridge Street, Apartment
1, Cazlisle, Cumberland County, Pennsylvania 17013.
3. The Plaintiff and Defendant aze sui juris, and Plaintiffhas been a bona fide resident
of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months
immediately preceding the filing of this Complaint in Divorce.
4. The parties were married on October 1, 1983 in Carlisle, Cumberland County,
Pennsylvania.
5. The marriage is irretrievably broken. The foregoing facts aze averred and brought
under Section 3301(c) or 3301(d) of the Divorce Code of 1980, as amended.
6. The Plaintiffhas been advised of the availability of counseling, and that the Plaintiff
may have the right to request that the Court require the Parties to participate in counseling, and
Plaintiff waives same.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce,
divorcing the Plaintiff from the Defendant.
Respectfully submitted,
& ASSOCIATES, P.C.
Attorney ID No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717)249-5373
Attorneys for Plaintiff
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel in the preparation of the lawsuit. The language of the document is that of counsel
and not my own. I have read the Complaint in Divorce and to the extent that the document is
based upon information which I have given to my counsel, it is true and correct to the best of my
knowledge, information and belief. To the extent that the content of the document is that of
counsel, I have relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities, which provides that if I make knowingly
false averments, I may be subject to criminal penalties.
Catherine J. Walters
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CATHERINE J. WALTERS,
Plaintiff
CIVIL ACTION -LAW
v. No. 2007- 1222
NORMAN E. WALTERS,
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this ~~ay of April, 2007, I, Sean M. Shultz, Esquire, hereby certify that the
following person was served with a True and Correct copy of the Complaint in Divorce filed in the
above-referenced matter. The Complaint was mailed on March 8, 2007, but actual service took place
on Mazch 29, 2007, by Defendant signing for a copy of the Complaint in Divorce which was mailed
in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage
Prepaid, addressed as follows:
Norman E. Walters
130 W. Ridge Street, Apt. 1
Carlisle, Pennsylvania 17013
A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by
reference incorporated herein and made a part hereof.
F:\User Folder\Fvm Dots\Gendocs200T406]-1 cert.service. Wpd
Respectfully submitted,
KNI~iT & ASSOCIATES
Sean M. Shultz, Esquire ~
Attorney ID No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17015
(717) 249-5373
Attorneys for Plaintiff
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