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Home My WebLink About99-04495Y } J} ? H .? u 'a 1 r?? r { rw k? ;l. . F ? M? • AM }1p I -10 ' Y t?. , ; ;F 4. 5 {j u? }'r u A? iv 1 ?s^v I_1 SHIRLEY G. SOWDEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. / NO: 4 9 - I1?/9s 0i ui L`? ROGER C. SOWDEN, Defendant CIVIL ACTION-LAW 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. 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, 1 Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 CONNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE GeunAdFA*Mstrator Cu?d. ?' . a?2 ASSocr'd>(?ov Carlisle, PA 17013 0l ?? bF2F- 7/7-aN9- ?//,L SHIRLEY G. SOWDEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO: ROGER C. SOWDEN, Defendant CIVIL ACTION-LAW COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Shirley G. Sowden, an adult individual, who currently resides at 3656 Chestnut Drive, Camp Hill, Pennsylvania, 17011. 2. Defendant is Roger C. Sowden, is an adult individual, whose residence is at 3656 Chestnut Drive, Camp Hill, Pennsylvania, 17011. 3. Defendant has currently been released from the Cumberland County Prison on ROR bail. 4. The Plaintiff has been a bona fide resident(s) in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on January 27, 1995, in Mechanicsburg, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The Plaintiff in this action is not a member of the Armed forces. 8. Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to the divorce decree being handed down by the court. 10. The marriage is irretrievably broken. 11. The Plaintiff avers that the Defendant, in violation of her marriage vows, has committed by cruel and barbarous treatment, endangered the life or health of the injured and innocent spouse. 12. The Plaintiff avers that the Defendant, in violation of her marriage vows, has offered such indignities to the innocent and injured spouse as to render that spouse's condition intolerable and life burdensome. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, MARSHALL, SMITH & HADDICK, P.C. ia un r. NurumKls, tsqulre At . I.D. No: 80411 20 uth 36'h Street Camp Hill, PA 17011 Attorney for Plaintiff SHIRLEY G. SOWDEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO: ROGER C. SOWDEN, Defendant CIVIL ACTION-LAW VERIFICATION I verify that the statements made in the foregoing complaint and divorce are true and correct. I understand that false statements herein are made subject to the penalties 18pa. c. s. §4904, relating to unsworn falsifications to authorities. DATE: --74RL199 s _h Lvnpr_? Shirley G. owden .?\ T '- in - `., - G J is .'? ? ? ? Q ? ? ' ? ? ? ? . ' ? ,..? ? _, , L ?? 1 2 Iw •E . I Complete Items 1 eno- -,? for additional services i e • Complete Items 3, eq a ib. • Print your name and auw,ss i on the reverse of this form no that we can I return this card to you. N Attach this form to the front of the mallplece, or on the back If space tiom not permit. 1.4 Write "Return Receipt Requested" on the meilplece below the snide number it Ins x m Ranipt win show to whom the article was delivered and the date e dsliw I 3. A icle Addressed to: 40. An $ r C. wd lei. Z 4b Sei g K?Gbl?prp 1C'/cmcx?JtAq Reg ?? R-l LL?r /?ctw\ Cen 1 also vlsh to receive the followin Aces (for an extra fee): 1. ? Addressee's Address 2. ? Restricted Delivery ? Express Mail //?' ! p • rLG?I /6U?, /(i1> 7. Date of II Q 6. Signature (Addressee) 8. Addr E and f I a 8 Bn to IAg t) V SO g PS a December 199 u.S.a.P.o.:laea•dor•sno DOMES ' ? Insured ? COD ? Return Recelpt for C a; r' i i SHIRLEY G. SOWDEN, Plaintiff VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 994495 Civil Term ROGER C. SOWDEN, Defendant CIVIL ACTION-LAW AFFIDAVIT OF SERVICE I, Jason P. Kutulakis, hereby certify that I served a true and correct copy of the Complaint Under Section 3301(c) of the Divorce Code, upon the Defendant, receipt of which is acknowledged on the attached return receipt card on July 29, 1999. Respectfully submitted, MARSHALL, SMITH & HADDICK, P.C. Date: September 13, 1999 Jas9fi P. Kutulakis, Esquire Atto ney I.D. No: 80411 20 South 36th Street Camp Hill, PA 17011 (717)731-4800 Attorney for Plaintiff A CERTIFICATE OF SERVICE AND NOW, this 13th day of September, 1999, I, Jason P. Kutulakis, Esquire, hereby certify that I did serve a true and correct copy of the foregoing Affidavit of Service upon all counsel of record and unrepresented parties by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: VIA FIRST-CLASS MAIL Roger C. Sowden Keeber Company 5045 Ritter Road Mechanicsburg, PA 17055 4sP. squir e ??> - .•. ?'- ,; ,.. x U a ~ a A u ei o ?,,a F x h ? y Y F' 0. (y axx? .a N ?, a ti ? v; V] c1 z ? i . V ,? U H ?+