HomeMy WebLinkAbout00-06203
,"" -~,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO, JOOO - &J-03,
TINA M, ASKINS,
v,
MICHAEL S, ASKINS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND.AND CLAlMRIGHTS
YOU HA VB BEEN SUED IN COURT, If you wish to defend against the claims set forth
in the foUowingpages, 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. Ajudgment 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 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 of the
Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania,
17013.
IF YOU DO NOT Fn.E A CLAIM FOR ALIMONY, DMSION 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 SItOULD TAKE TIllS PAPER TO YOURLAWYER 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 LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania
(717) 249-3166
.;"
"c."..,.., ,'.- ..'"
, ._~
r <
.' ~-'
, .. .
Plaintiff
: IN THE COURT OF COMMONPLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO, tJv ~ (, .2.03 ~ I ~
TINA M. ASKINS,
v,
MICHAEL S, ASKINS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1, The Plaintiff is Tina M, AskinsJ an adult individual currently residing at 95 Arnold Road,
Enola, Cumberland County, Pennsylvania, 17025. Plaintiff's social security number is
184-48-8064.
2, The Defendant is Michael S, Askins, an adult individual currently residing at 95 Arnold
Road, Eno1a, Cumberland County, Pennsylvania, 17025. Defendant's social security
number is 193-56-5362,
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania, for a
period in excess of six (6) months immediately previous to the filing of this Complaint.
4, Plaintiff and defendant were married on August 19, 1979, in Dauphin County,
Pennsylvlll)ia.
5, There have been no prior actions of divorce or annulment between the parties in this or
any other jurisdiction,
6, Plaintiff and defendant have been separated since September 5, 2000,
7. The grounds for divorce are: The marriage is irretrievably broken.
8, Plaintiff and defendant have two children under the age of 18,
- , ,,"
..< ,
'-.
9, Plaintiff has been advised that counseling is available and that plaintiff mat have the right
to request that the court require the parties to participate in counseling, Plaintiff does not
want said counseling,
WHEREFORE, Plaintiff requests this Honorable Court enter a Decree of Divorce,
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 C, S, ~4904, relating to unsworn
falsificatiol} to <horities,
.i/Jtf1 <1//, A~'
fina M. Askins, Plaintiff
Dated: 9-1/. ()O
t~ ~O_2
William T, Smith, Esquire
Attorney I,D, No, 06887
3747 Derry Street
Harrisburg, P A 17111
(717) 561-2677
~_. ,
. ',,-"
. '.
~, , ' "- -'.~
,'"
.
~ ~ "'~_.
!\
f
"
^
.,.-,.p
,~"'" "
- <. e..,,,,'I'
',"",,~,.,;_^~',-"t,,- ", '.v''^''-';.;_''<-Y''l"~''"''---'''"]~'';;''C;;~;",,,d,I,~,'_"",,, "1 "'","-):'
~ \\ ~
it: i'\' ~
.!l::.
'""'-.. d
0 -l::'
0 "'-l
..0 ........
0
-C.
~~g~-:
"""-- ;-::c'.,
~ 1'< cl,. ;;t c:
",-) <.-) ::::: .
g d~Ei
::?:
'-1 ~ :<:
..,h "'-
---}~
V\
~
\.&'
~
't:;
(')
c::
..,J ~...
~
C)
C:.'
~/)
~"~I
'";:J
''''':'
c..,,:,
:""
fJ"l
n .,~,,J!Iw ^.~"
~~_~~Q"f~~),",?W"~".~e'c'","",;",,,,,,,,",,,,ifi.~~Q, _,_ ,mid"