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Created: IIII4f0003:25:45PM
Revised: lI1I4/0003:31:43PM
8419,3
GREGORY A. BLAKE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000- ?D rr ~ I~
CIVIL ACTION - LAW
VIRGINIA BLAKE,
Defendant
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. ]f 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 Jose money or property or other rights important to you, including custody
or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available at the Domestic
Re]ations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this Jist is kept as a
convenience to you and you are not bound to choose a counselor from the list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you
desire to pursue counseling, you must make your request for counseling within twenty (20) days of
the date on which you receive this notice. Failure to do so will constitute a waiver of your right to
request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT 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
Telephone (717) 249-3166
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GREGORY A. BLAKE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000- 86?r ~ r..u.-
CIVIL ACTION - LAW
VIRGINIA BLAKE,
Defendant
IN DIVORCE
COMPLAINT
1. Plaintiff is Gregory A. Blake, who currently resides at 31 Woodview Drive, Mt.
HoJly, Cumberland County, P A.
2. Defendant is Virginia Blake, who currently resides at 31 Woodview Drive, Mt. HoJly,
Cumberland County, PA.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing ohhis Complaint.
4. The Plaintiff and Defendant were married on May 24, 1998 in Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiffhas 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.
8. Plaintiff requests the Court to enter a decree of divorce.
MARTSON DEARDORFF WILLIAMS & OTTO
,..--1 .. .1 e- _
Byl ~ l V\tV<.-- - "
Thomas J. Will , Esquire
Ten East High eet
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date; November 15, 2000
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VERIFICATION
The foregoing Divorce Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. The language of the document is that of counsel and not
my own. I have read the document and to the extent that it is based upon information which I have
given to my counsel, it is true and COrrect to the best of my knowledge, information and belief. To
the extent that the content of the document is that of counsel, I have relied upon counsel in making
this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to crimina] penalties.
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Grego A. ake
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F:\FILES\DA TAFILE\Gendoc_cur\84193_aff.lItde
Created: 11114/00 03:25:45 PM
Revised: 11/29/00 02:35:35 PM
8419.3'
GREGORY A. BLAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-8088
CJV]L ACTION - LAW
VIRGINJA BLAKE,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND )
I hereby certifY that a copy of the Complaint in Divorce was mailed to Defendant Virginia
Blake at 31 Woodview Drive, Mt. Holly, P A 17065 on November 16, 2000 by certified mail,
restricted delivery, return receipt requested.
Attached is the Post Office return receipt signed "Virginia D. Blake" and dated November 18,
2000.
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Sworn to and s~~~bed
before me this.;iOr'day of
November, 2000.
~lJ. 04dd~
NOTARIAL SEAL
TRIOlA D. ECKENROAD, Notary Public
C lisle Boro., Cumberland Coun~
. . . 23, 2004
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