HomeMy WebLinkAbout01-1699 FX
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SUSAND. WALTERS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
~ No. ol-II.oQ9 cl~l'l
Civil Term
LESTERC. WALTERS,
Defendant
: 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.
Where 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
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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
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SUSAND. WALTERS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 01-1C,11
Civil Term
LESTERC. WALTERS,
Defendant
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Susan D. Walters, an individual suijuris, who has resided at 820 Center
St., Enola, Cumberland County, Pennsylvania, since 1973.
2. Defendant is Lester C. Walters, an individual sui juris, who has resided at 820 Center
St., Enola, Cumberland County, Pennsylvania, since 1973.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on July 13, 1963 in Enola, Cumberland
County, Pennsylvania.
5. There has been one prior actions of divorce between the parties; however, this action
was discontinued and dismissed approximately 20 years ago.
6. 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.
7. Plaintiff and Defendant have three children together; however all are adults above the
age of eighteen.
8. Plaintiff and Defendant are both citizens ofthe United States of America.
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9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of any of its allies.
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10. The Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken; and/or
(b) That the Defendant has offered such indignities to the Plaintiff, the innocent
and injured spouse, as to render her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests the court to enter a decree in 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 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
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Susan D. Walters, Plaintiff
Respectfully subruitted,
Date: 3.- '2-( -01
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e Adams, Esquire
1. . No. 79465
7 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTWF
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SUSAND. WALTERS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 01 - 1699 Civil Term
LESTER C. WALTERS,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE OF
NOTICE TO DEFEND AND COMPLAINT
AND NOW, this March 30, 2001, I, Jane Adams, Esquire, hereby certify that
on March 28,2001, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT
were served, via certified mail, restricted delivery, return receipt requested, addressed to:
Lester C. Walters
820 Center St.
Enola, Pa. 17025
DEFENDANT
Respectfully Submitted:
Jan Adams, Esquire
I. . No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTITF
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