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1.
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MELANIE L. ANTONIO,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. '17- 4 SJ () (1/.'1)-'.)(_
v.
DAVID M. WHIPKEY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
HOTICI TO DIFIND AND CLAIM ALL 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 within twenty (20) days. 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 counselor$ is available in the
Office of the Prothonotary, Cumberland County Courthouse, 1
Courthouse Square, 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TaE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Courthouse
1 Courthouse Square, 4th Floor
CarliSle, Pennsylvania 17013
(717) 240-6200
MILAMII L. ANTONIO,
Plaintiff
v.
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IN THI COURT or COMMON PLBA8
CUMBIRLAND COUNTY, PINN8YLVANIA
NO. 'r/- ,/j:/, (',..I -/.',.
DAVID M. WHIPKBY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE U~
8BCTION 3301 (0) or THI DIVORCI CODI
1. Plaintiff is Melanie L. Antonio, an adult individual who
currently resides at Box 158, Beallsville, Washington County,
Pennsylvania, 15313.
2. Defendant is David M. Whipkey, an adult individual who
currently resides at c/o Gerald Swift, 2703 Society Hill, Apt. 302,
camp Hill, Cumberland County, Pennsylvania, 17011.
3. Both Plaintiff and Defendant have been bona fide residents
in the Commonwealth for at least six (6) months immediately
previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on December 30,
1995, in Beallsville, Washington County, Pennsylvania.
5. There have been no prior actions for divorce or annulment
between the parties.
6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. Neither the Plaintiff or Defendant is a member of the
Armed Services of the United states or any of its Allies.
8. The Plaintiff avers that the ground on which the action
is based is that the marriage is irretrievably broken.
9. Plaintiff avers that there is a child of the parties
under the aqe of 18, namely: Jacob O. Whipkey, born June 10, 1996.
WHEREFORE, Plaintiff requests the court to enter a Decree in
Divorce dissolvinq the marriaqe between the parties pursuant to
Section 3301 (c) of the Divorce Code of 1980, as amended.
Dated: ~
Respectfully submit~.d,
t l'./l
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Joanne H. Clouqh Esquire
845 Sir Thomas Curt, Suite l1A
HarrisbuI'q, PA 109
Attorney t.O. No. 36461
(717) 540-5100
Attorney for Plaintiff
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CBRTI.ICATB ot .B.VIeB
AND NOW, this
day of
, 1997, I,
Kristie L. Shirk, Paralegal to Joanne H. Clough, Esquire, hereby
oertify that I have served a copy of the foregoing Divoroe
Complaint upon Defendant by plaoing a copy of the same in the
United states Mail, First Class, postage pre-paid at the address
set forth below:
David M. Whipkey
clo Gerald swift
2703 society Hill, Apt. 302
Camp Hill, PA 17011
I
Kristie L. Shirk Paralegal to
Joanne H. Clough, Esquire
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