HomeMy WebLinkAbout98-01145
IN THE COURT OF COMMON PLEAS OF THE _ JUDICIAL DISTRICT
OF PENNSYLVANIA COUNTY CUMBERLAND
DANIEL KEITH JONES
Plaintiff
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CIVIL ACTION - L~W
9~ -1/ALt; Cu,1 TERM
CASE NO.
LINDA JEAN JONES
Defendant
IN DIVORCE
COMPLAINT UNDER SECTION 330J(c) OR 3301(d) OF THE DIVORCE CODE
I. Plaintiff is DANIEL KEITH JONES who resides at; 1004 Holly Pike; Carlisle, Pennsylvania
17013,
2. Defendant is LINDA JEAN JONES who resides at: 10366 SW 21251; Miami, Florida 33189,
3. 181 Plaintiff and/or 0 Defendant have been a bona fide resident(s) ofthe Commonwealth of
Pennsylvania for at least six months immediately prior to commencement of this action.
4. Plaintiff married Defendant on March 21, 1991 at Miami, Florida. Attached hereto and marked
as Exhibit "A" is the certificate of marriage evidencing said marriage.
5. Neither plaintiff nor defendant is in the military or naval service of the Unites States or its allies
within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its
amendments.
6. There has been no prior action of divorce or for annulment between the parties,
7. The marriage is irretrievably broken.
8. After 90 days have elapsed from the date of filing of this Complaint, Plaintiff intends to file an
affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit.
9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the
right to request that the Court require the parties to participate in marriage counseling,
Complaint for Divorce; Page 1
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