HomeMy WebLinkAbout01-5807BARBARA L. ADAMS,
Plaintiff
V
GEORGE J. ADAMS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01- ~.~07 CIVIL ACTION
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM 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. 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office
at the Cumberland County Courthouse, 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 THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
BARBARA L. ADAMS,
Plaintiff
V
GEORGE J. ADAMS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01- ~'~ '7 CIVIL ACTION
: 1N DIVORCE
COMPLAINT
Plaimiff, Barbara L. Adams, by her attomeys, Broujos & Gilroy, P.C., sets forth the fbllowing:
1
Plaintiff, Barbara L. Adams, is an adult individual residing at 215 North 26th Street, Camp Hill,
Cumberland County, Pennsylvania.
2
Defendant, George J. Adams, is an adult individual residing at 510 Dumberton Drive, New Oxford,
Pennsylvania 17350, Pennsylvania.
3
The parties were married on August 20, 1966, in Harrisburg, Dauphin County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least
six months prior to the commencement of this action.
5
There have been no prior actions for divorce or annulment in this or any other jurisdiction within the
knowledge of the Plaintiff.
6
In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is
irretrievably broken.
WHEREFORE, the Plaintiff`requests your Honorable Court to enter a decree divorcing her from the
Defendant.
Respectfully submitted,
Carlisle, PA 17013
(717) 243-4574
Supreme Court ID No. 29943
I verify that the statements in the foregoing pleading are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom
thlsification to authorities.
Barbara L. Adams
ADAMS BARBARA L
vs
ADAMS GEORGE J
In The Court of Common Pleas of
Cumberland County, Pennsylvania
File No.
2001-05807
STATEMENT OF INTENTION TO PROCEED
To the Court:
intends to proceed with the above captioned matter.
Date:_.
HAROLD S. IRWIN, III
ATTORNEY ID NO. 29920
64 SOUTH PITT STREET
CARLISLE PA 17013
(717) 243.6090
ATTORNEY FOR PLAINTIFF
BARBARA L. ADAMS, : IN THE COURT OF CCIMMON PLEAS OF
Plaintiff : CUMBERLAND COUN'rv, PENNSYLVANIA
VB. : CIVIL ACTION - LAW
GEORGE ... ADAMS, : NO. 2001 - 5807 CIVIIL TERM
Defendant : IN DIVORCE
PRAECIPE FOR WITHDRAW AND ENTRtY OF APPEARANCE
OF COUNSEL OF RECC)RD
TO THE PROTHONOTARY:
Please withdraw the appearance of HUBERT X. GILROY, ESQUIRE as attorney of
record for the plaintiff in this matter.
February~,2005
ClfJ-
BROUJOS & GILR
4 North H:anover Street
Carlisle, PA 17013
(717) 243.4574
Please enter the appearance of HAROLD S. IRWIN, III, ESQUIRE as attorney of record
for the plaintiff in this matter. I
February ..2.., 2005
IRWIN LAW OFFICE
64 South Pitt Street
Carlisle, P'A 17013
717-243-6090
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