HomeMy WebLinkAbout03-0588DOROTHY K. WASHINGTON,
Plaintiff
FREDERICK F. WASHINGTON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION L_.AW
No.
IN DIVORCE
NOTICE
You have been sued in court. It' you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you £ail 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 the
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation o£your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office o£ the
Prothonotary at the Cumberland County Court House, High and Hanover streets, Carlisle.
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 TI-IEM.
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 Liberty Avenue
Carlisle, PA 17013
Phone: (717) 249-3166
DOROTHY K. WASHINGTON,
Plaintiff
FREDERICK F. WASHINGTON,
Defendant
· 1N THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· CIVIL ACTION LAW
.No.
· IN DIVORCE
COMPLAINT
1. Plaintiff is Dorothy K. Washington, who currently resides at 1031 North Field Drive, Carlisle,
Cumberland County, Pennsylvania, since approximately December 18, 2002·
2. Defendant is Frederick F. Washington, who currently resides at 436 N. Pitt Street, Carlisle,
Cumberland County, Pennsylvania, since approximately February of 2002.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least
six months immediately previous to the filing of this Complaint.
4. Plainfiffand Defendant were married on June 11, 1988, in Carlisle, Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in this
or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiffhas been advised that counseling is available, and that Plalntiffmay have the right to
request that the Court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaimiff respectfully requests this Honorable Court to emer a Decree in
Divorce and such other Orders as may be just and appropriate.
Respectfully submitted,
ROMINGER & BAYLEY
Michael J. Wh~e, ] q '
155 South Hanover Street
Carlisle, PA 17013
717-241-6070
Supreme Court ID #89028
Attorney for Plaimiff
DOROTHY K. WASHINGTON,
Plaintiff
FREDERICK F. WASHINGTON,
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
· CIVIL ACTION LAW
No.
: IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to
unsworn falsification to authorities·
Date: ~- %03
~orothy ~. Was~ngtofi;~, Plaintiff
DOROTHY K. WASHINGTON,
Plaintiff
FREDERICK F. WASHINGTON,
Defendant
· IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
:No.
· IN DIVORCE
CERTIFICATE OF SERVICE
I, Michael J. Whare, Esquire, attorney for Dorothy K. Washington, do hereby certify that I
this day served a copy ofPlainthT s Complaint upon the following by depositing the same in the
United States Mail, remm receipt requested and first class postage prepaid, at Carlisle,
Pennsylvania, addressed as follows:
Frederick F. Washington
436 N. Pitt Street
Carlisle, PA 17013
Dated: February 7, 2003
Michad J. Whare, Esquire
Attorney for Plaintiff