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HomeMy WebLinkAbout01-05807BARBARA L. ADAMS, Plaintiff v GEORGE J. ADAMS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.O1- IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS CIVIL ACTION 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 is 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 BARBARA L. ADAMS, Plaintiff v GEORGE J. ADAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.01-5667 CIVIL ACTION IN DIVORCE COMPLAINT Plaintiff, Barbara L. Adams, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff, Barbara L. Adams, is an adult individual residing at 215 North 26`" Street, Camp Hill, Cumberland County, Pennsylvania. 2 Defendant, George J. Adams, is an adult individual residing at 510 Dumberton Drive, New Oxford, Pennsylvania 17350, Pennsylvania. 3 The parties were married on August 20, 1966, in Harrisburg, Dauphin County, Pennsylvania. 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 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 6 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 enter a decree divorcing her from the Defendant. Respectfully submitted, Hubert X. Troy, Esquire Attorney r Plaintiff Broujo & Gilroy, P.C. 4 No rtfi Hanover Street Carlisle, PA 17013 (717) 243-4574 Supreme Court ID No. 29943 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 unworn falsification to authorities. arbara L. Adan., 9 (J? In The Court of Common Pleas of Cumberland County, Pennsylvania ADAMS BARBARA L VS ADAMS GEORGE J File No. 2001-05807 STATEMENT OF INTENTION TO PROCEED To the Court: X intends to proceed with the above captioned matter. Date: O b ? Attorney for . C fy % c !! ?"- ?_. RJ ?? ..,5 - 'J. _. i"; Z r _t ri !.': ?? ?.. 1 I?? _ _ _ _ _ _.. H?fS?''i'<?.ans»€€vwemmat9r ?r+5 ?.??'cs¢. ?.erta q?qy?< rz,i?i'w„?j ,u?}.-"5R9E.%?t _ _ _ P?4'. HAROLD S. IRWIN, 111 ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF BARBARA L. ADAMS, Plaintiff Vs. GEORGE J. ADAMS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2001 - 5807 CIVIL TERM : IN DIVORCE PRAECIPE FOR WITHDRAW AND ENTRY OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Please withdraw the appearance of HUBERT X. GILROY, ESQUIRE as attorney of record for the plaintiff in this matter. ^ February, 2005 HUBERT X. GILROY BROUJOS & GILROYY 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 Please enter the appearance of HAROLD S. IRWIN, III, ESQUIRE as attorney of record for the plaintiff in this matter. February 2005 IRWIN LAW OFFICE 64 South Pitt Street Carlisle, PA 17013 717-243-6090 ?,..? ice"} \J 31 MW .T. ?j (? Curtis R. Long Prothonotary ®ffire of the i9rotbonotarp QCumberranb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor I - S'? 7 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6571