HomeMy WebLinkAbout03-1543BLAINE E. SMITH,
Plaintiff
V
LAURIE A. KLENSING-SMITH,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 03 - /,5~/.~ CIVIL ACTION - LAW
: 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 are 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
BLAINE E. SMITH,
Plaintiff
V
LAURIE A. KLENSING-SMITH,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 03- /'~,"~..~ CIVIL ACTION- LAW
: IN DIVORCE
COMPLAINT
Plaintiff, Blaine E. Smith, by his attorneys, Broujos & Gilroy, P.C., sets forth the following:
1
Plaintiff, Blaine E. Smith, is an adult individual residing at 255 Walnut Street, Shippensburg,
Cumberland County, Pennsylvania.
2
Defendant, Laurie A. Klenzing-Smith, is an adult individual residing at P.O. Box 422, 3897
Lincoln Street, Scotland, Franklin County, Pennsylvania 17254.
3
The parties were married on October 22, 1993, in Hagerstown, Maryland.
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
Plaintiff has been advised that counseling is available and that Plaintiff may have the right to
request that the Court require the parties to participate in counseling.
6
There have been no prior actions for divorce or annulment in this or any other jurisdiction
within the knowledge of the Plaintiff.
7
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 decree that the Plaintiff be
divorced from the Defendant.
BROUJOS & GILROY, P.C.
B
Hu(~rt X. Gilroyd~squire
Attorney for P~intiff
Broujos & ~ilroy, P.C.
4 North Hanover Street
Carlisle, PA 17013
717 - 243-4574
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
unsworn falsification to authorities.
Blaine E. Smith