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HomeMy WebLinkAbout99-04362F 1 ri C6 ¦- 1 'Z0 HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 35 EAST MION STREET CARLISLE PA 17013 (717) 243.8090 ATTORNEY FOR PLAINTIFF GREGORY B. WEBER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 99 - Y13 t- ,CIVIL TERM KATHY J. WEBER, 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 GREGORY B. WEBER, Plaintiff v. KATHY J. WEBER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - VJ4' -CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) 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 Gregory B. Weber, an adult individual residing at 72 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Kathy J. Weber, an adult individual residing at 72 Peachy Ann Drive, Newville, Cumberland County, Pennsylvania 17241. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. le 4. The plaintiff and the defendant were married on April 0, 1992, in Newville, Cumberland County, Pennsylvania. 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 16 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. July 9, 1999 HAROLD S. IRWIN, II Attorney for Plaintiff 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 GREGORY B. WEBER, Plaintiff V. KATHY J. WEBER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0.99 • CIVIL TERM 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. 1 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. July 9, 1999 GREGORY B AB intiff J ?i M r ?f U J O n 'y rv~i E P4 E S z E w N o 1 0.4 H W w a ~¢ U ? D HV V q .,' C d 4 y W 2 ?¢ o N a a ? a? a 4 ? ? ¢ =a O E VI U H Q Vi ' > a Q p w. V] Z ?2 = z `? e t? N 3 O 04H i OQ ?y V U H o, a pa N U N h ¢ V E x C?7 z H W E HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HION STREET CARLISLE PA 17013 (717) 2438090 ATTORNEY FOR PLAINTIFF GREGORY B. WEBER, Plaintiff V. KATHY J. WEBER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99.4362 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO 1920.4 (a)(1)(1) 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 July 22, 1999, by certified mail "restricted delivery", addressed to her at 72 Peachey Ann Drive, Newville, Pennsylvania 17241 certified mail, return receipt No. Z 126 560 962. 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 falsification.to authorities. July 26, 1999 Harold S. Irwin, III Attorney for plains SENDER: M ecowplete ne t wKV" x for a0etlorW morose. I also wbh to rW" Me :Cw MteIM=3,4a,endb. Pek to ur 11 Y1e Ord eeerwe M 00 re`eree or this km a M we un man ere fog01wingservioss(for an ehbs fN): y ou . M Mbaderam Mee hod dtho MW%MM Or or1 the b[M a r ea dm not ' . p A 1.0 Addressee s Address gThI M RSOW we wMe1 tle was dMwed eW tle eW Restricted t" derv«ed. consult poetrnaebrfor ss. 3. Artlds Addressed to: 4a. Ardde Number KATHY J WEBER Z 126 560 962 72 PEACHEY ANN DR 4b. Service Type 0 Registered 12 cerY NEWVILLE PA 17241 0 Fxprm Mall 0 Insured 0 Return ReoNpt for Merdwandse 0 COD OelW to addressee only 7. Date of Dolinry _ w- V 5. R Ned By: (PMI Neme) = B. Addressee's Address (Only N7equesbd WL5 E 7 and fee is paid) g 6. Slgn t c Addressee or Agent) s X 1?ec? PS Form 381 December 1994 102 595.97.8-0179 Domestic Retum Bm of d? v? S O N ao d q q C rV rd > -0 u a 0 -z (pf Rn .6 cu V•t' c a el dl O o a fu tYUzo? ra N I1( N, y ? N 3 v V_ Y E a ' Zz, E _ 4 . Q \l f.66t 4-M DDVU -Jud Sd C) T 'cr tT 1 1?. r. •D -fn rti CA U w•