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M. JANE MATHEWS,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION. DIVORCE
PlalntlH
VB.
STANLEY D. MATHEWS,
Defendant
NO. 98. .),,',.'j
IN DIVORCE
CIVIL TERM
~ IN DIVORCE
M. Jane Mathews. Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER &
LINDSAY, P,C., respectfully represents:
1, The Plaintiff is M. Jane Mathews, who currently resides at 129 Partridge Circle. Carlisle,
Cumberland County, Pennsylvania, where she has resided since 1992.
2. The Defendant is Stanley D. Mathews, who currently resides at 284 Sassafras Court,
Warrington, Bucks County, Pennsylvania, where he has resided since 1997.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth
of Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4, The Plaintiff and Defendant were married on December 31, 1976. at Bucks County.
Pennsylvania.
5. That there have been no prior actions of divorce or for annulment between the parties
In this or in any other jurisdiction.
6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage Is
Irretrievably broken and Plaintiff Is proceeding under Sections 3301 (c) and/or (d) of the Divorce
Code,