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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.
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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
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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
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