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HomeMy WebLinkAbout01-06664 . . . vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH S. DETE, Plaintiff CIVIL ACTION - LAW NO. 0/-l.1..(",/ ~ ~ GEORGE D. DETE, Defendant 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 foregoing pages, you must take prompt action. You are warned that if you fail to do so, the :1 case may proceed without you and a decree in divorce or annulment may be entered II against you by the court. A judgment rnay also be entered against you for any other claim " : or relief requested in these papers by the Plaintiff. You rnay lose money or property or I 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 rnarriage counseling. A list ofrnarriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, P A 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORGE 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 Telephone: (717) 249-3166 :!'J' c . ~-~ < vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH S. DETE, Plaintiff CIVIL ACTION - LAW NO. 61 -<'{.t.. \{ ~ '1fL<.-... GEORGE D. DETE, Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Cornp1aint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this 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 days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. <1'1 - ': L_','.,,_'_"_ ....~. vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH S. DETE, Plaintiff CIVIL ACTION - LAW NO. 01- c.(. c.'f ~ T.Q.o.... GEORGE D. PETE, Defendant IN DIVORCE III COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, ELIZABETH S. DETE, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is ELIZABETH S. DETE, an adult individual who currently resides at 328 West Willow Street in Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is GEORGE D. DETE, an adult individual who currently resides at 328 West Willow Street in Carlisle, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents ofthe Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 8 August 1987 in Lancaster, Lancaster County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. ~ Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 ~ . ,;P'. .. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Cornp1aint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ! / - I I - 0 j ~~~ j,i~ ELiz TH S. DETE ' -",-,.". ..~ ~ ,. k, ~~,__"J~U~_.,_ )lLJI:1iIJ,", > " .' , "'"- ~ .-~. . '''''''.. ~-- ._-;~,-";,h, .- -- ~-'- 'r ,--,.,', .'e" r r ..... "" ...., -... -<;> I:-' l>.> -0 l>> {' It "",' ;- ~- "-.~=>,~~'-~~-< -, --,....,-.~qj'~'" "'N"-,",~",>"", ~ o c <" -at'S mn-, ~~ ""'-.),' 2T ~2~f ~CJ 'l-';:,..-- z>--< ~c~~ z -1 -:; \!) co ;'>~- ... ~ ~ ;'-...) CD -i', r.,.) -:--~f? ~~t ::0 -< ...j ~~~tm'~.'~*~Wl!%''''~~'t'j':jre:i'_:,..:i,",N~f,.,~_",~,~~rw:'~:;SW!jijW{hl,~lr'ii'1-1ll!~~\'ll!IiIl~~<~!lf :~=~-~ !r ELIZABETH S. DETE, PLAINTIFF ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 01-6664 CIVIL TERM GEORGE D. DETE, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE 1 hereby enter my appearance for the Defendant, George D. Dete, in the above- captioned action. I acknowledge receipt of a true and correct copy of the Complaint in Divorce filed in the above action on behalf of the Defendant. Date: IZ;~/ n, Esquire 78 West Pom t Street Carlisle, Pa 17013 Attorney for Defendant Supreme Court ID # / ~ Jl:C? >, "-', - ':). <,',"'-~"--~' 'I:~!. ,,~~_ = ~~,~~,.~ -~ - ~- " -,- ,. "'.h, .'";".I'_~ ~.., ,. ',v',-, '.>> '"'",.-","'~""<<"'-"~'- ''.!''''IT''''''' "",,. ,"" : . 0 c:.' r- C "",I ~ '-'1 l'!6~ 0 ::.::::1 n'f" P" -;.-7--:,: -. ~:;~ . ~- j,0 ~:) 2. ~~,' --] SJ -<. (,) -< O'1''',Wr ~ /?II ~ ,,". _,_~ _ J.TlWJ?'T~1T,~>;-:. _',_" ,,?_..f>1ti!1~r,J~Tn~',~')7n~~W1f-M-M~'<,V'l'!<1't~'~,,*lf-}..~~~~~~,~,,~l<ji%l~~"~}"i~~~~t:_"TJ:~Hf~E~~