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Home My WebLink About00-06612 ..-' "" -, ~-~ '"-I "..- -,.- -,.","n',",." ,',"'-'"'",, '" _'~;" ,~ ,- l;.iO\ HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF DENNIS E. MATTHEWS, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTI9.N . LAW = NO. 00 . (/..t;/J.. CIVIL TERM BONITA K. MATTHEWS, Defendant = IN DIVORCE NOTICE 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 in 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 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, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-243-3166 J ~-r~ "n,..','" -...- < " 'L,..;<";_"' ";"", \,,,,,,. >"C<!S,^ ,',-"- "-">L_>_,,,.;--, _ ",'~ '"'j ,. DENNIS E. MATTHEWS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00 . Ib I./il- CIVIL TERM BONITA K. MATTHEWS, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 ~ OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Dennis E. Matthews, an adult individual residing at 115 Woodlawn Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Bonita K. Matthews, an adult individual residing at 115 Woodlawn Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on June 27, 1965, in Mt. Holly Springs, Pennsylvania. - ...""- " -. '~ - ',-'" , . -""-",~ -, '" -~ ;,:--'~'--- -,- -~,'-j . 5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 September 29, 2000 relating to unsworn falsification to authorities. U DENNIS E. MATTHEWS, Plaintiff HAROLD S. IRWIN, III Attorney for Plaintiff 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 ,;"'---~-- ",I,; "'I '.' ,>._,,, "~ "'_d_', ,__. ~.' ';',"1"_,_' ""__:'," ,_ .~,' ~_ 6"~ DENNIS E. MATTHEWS, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTION - LAW = NO. 00 . G,t./2.. CIVIL TERM BONITA K. MATTHEWS, Defendant = = IN DIVORCE PLAINTIFF"S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. September 28, 2000 ~~g DENNIS E. MATTHEWS, Plaintiff - .'.,"--;:"- ",;t-:"", ," ---" ~* ',---. ;' HAROLD S. IRWIN, III ESQ. ATTORNEY ID NO. 82585 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243.6090 ATTORNEY FOR PLAINTIFF DENNIS E. MATTHEWS, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTION. LAW = NO. 00 - 6612 CIVIL TERM BONITA K. MATTHEWS, Defendant = IN DIVORCE AFFIDAVIT OF SERVICE OF COM,PLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 C!tltllitl NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about October 17, 2000, by certified mail "restricted delivery", addressed to the defendant at 13 Woodlawn Lane, Carlisle, PA 17013, Certified Mail Receipt No. 7099-3220-0011-0097-67033 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsificption to authorities. November 16, 2000 Harold S. Irwin, III Attorney for plainti .... LI "-' '"""I "0'.",,', L;~_ ,- ;' . Complete Ite",~'H',12:~~d 3. Also co~pi~te " ' item 4 if Re~t~cted iDelivery is desired. . Print Y-,-Qur na~:e !an~, address on the reverse so that we can_~r'n the'card to you. . Attach this car~'lllthe back of the mailpiece, or on the fronpf space permits. 1. Article Addressed to: (J;JJ In/ .r. /YJd77/hwS If) tJOt1{j"~N L.mVz. ~t.15Vi III /71/'1 D. Is delivery address different from item 1? If YES, enter delivery address below: 3. 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