HomeMy WebLinkAbout98-00167
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KIM S, HOWELL, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs, ) CIVIL ACTION - LAW
)
) NO, 9 J, II, 'I CIVIL TERM
DALE A. HOWELL, )
Defendant ) IN DIVORCE
NOTICE OF A V AILABlLlTY O:f COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have be"n named as the Defendant in a Complaint in a divorce proceeding filed in the Court of
Common Pleas of Cumberland County, This notice is to advise you that in accordance with Section 3302(d)
of the Divorce Code, you may request that the court require you and your spouse to attend marriage
counseling prior to a divorce being handed down by the court, A list of professional marriage counselors is
available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised
that this list is kept as a convenience to you and you are not bound to choose a counselor from this 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 days of
the date on which you receive this notice, Failure to do so will constitute a waiver of your right to request
counseling,
KIM S, HOWELL, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYL VANIA
)
vs, ) CIVIL ACTION - LAW
)
) NO, 9 f - It I' CIVIL TERM
DALE A, HOWELL, )
Defendant ) IN DIVORCE
COMPf.,AINT IN DIVORCE
AND NOW comes the above-named Plaintiff, Kim S, Howell, by her attorney, Samuel L. Andes,
and makes the following Complaint in Divorce:
1. The Plaintiff is Kim S, Howell, an adult individual who currently resides at 935 Belle Vista Drive,
Enola, Cumberland County, Pennsylvania,
2, The Defendant is Dale A Howell, an adult individual who currently resides at 107 High Street,
Duncannon, Pennsylvania,
3, Both the Plaintiff and Defendant have been bona lide 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 6 June 1986 in Camp Hill, Pennsylvania,
5, There have been no prior actions of divorce or annulment between the parties,
6, This marriage is irretrievably broken,
7, Plaintiff has been advised oCthe availability of marriage counseling and the Plaintiff may have the
right to request that the Court require the parties to participate in counseling,
COUNT I-IRRETRIEVABLE BREAKDOWN
8, The Plaintiff requests this Court to enter a Decree of Divorce,
KIM S. HOWELL,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
CIVIL ACTION, LAW
NO, 98.167 CIVIL TERM
DALE A. HOWELL,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1, A Complaint in Divorce under Section 3301 (e) of the Divorc.e Code was filed on
13 January 1998 and was served upon the Defendant on or about 20 January 1998,
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant,
3, I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree,
4, I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final,
I verify that the statements made in this Affidavit are true and correct and 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,
if /1 ok
DATE ' . -
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KI S, HOWELL
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KIM S, HOWELL,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
VB,
CIVIL ACTION. LAW
NO, 98.167 CIVIL TERM
DALE A, HOWELL,
Defendant
IN DIVORCE
AEElQA'lll.OE.Ci.o.N.S.ENI
1. A Complaint In Divorce undm Soction 33011c) of the Divorce Code was filed on
13 January 1998 and was served upon the Defendant on or about 20 January 1998,
2, The marriage of Plaintiff and Defendant is irretrievably broken al1d ninety (90)
days have elapsed from tho dato of filing of the complaint and the date of service of the
complaint on the Defendant.
3, I consent to the entry of II final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree,
4, I have been advised of the availability of marriage counseling and understand that
the Court maintains o list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that tho statements made in this Affidavit are true and correct and I
understand that false statements herein are made subject to the penalties of 18 Pa, C.S,
Saetion 4904 relElting to unsworn falsification to authorities.
._.",.....~~(f,
DATE .
/.,.) /J7. 21
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DALE A, HOWELL
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