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WILLIAM R. CHENOWETH,
Plaintiff
V.
HOLLY E. HIGGINS CHENOWETH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - CIVIL TERM
CIVIL ACTION - LAW
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 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 the 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 at the
Cumberland County Courthouse, Carlisle, PA 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, PA 17013
Telephone: (717) 249-3166
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WILLIAM R. CHENOWETH,
Plaintiff
V.
HOLLY E. HIGGINS CHENOWETH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
i
No. y - 7f;,74 CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT
1. The Plaintiff in this action is William R. Chenoweth, an
adult individual, who currently resides at 905 South 29Ch Street, Camp
Hill, Cumberland County, Pennsylvania 17011.
2. The Defendant in this action is Holly E. Higgins Chenoweth,
an adult individual, who currently resides at 1101 #1 Columbus Avenue,
Lemoyne, Cumberland County, Pennsylvania 17043.
3. Both the Plaintiff and the Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage
on November 20, 1998, in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce = for annulment
between the parties hereto in this or any other jurisdiction.
-1-
6. The Plaintiff avers as the grounds upon which this action is
based is that the marriage between the parties hereto is
irretrievably broken.
7. The Plaintiff avers that one children has been born of this
marriage.
8. The Plaintiff has been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of di-
vorce.
I verify that the statements made in this complaint are true and
correct. I understand that false statements herein are made subject
to the penalties of 18 P.C.S. §4904, relating to unsworn falsification
to authorities.
Date: WILLIAM R. CHENOWETH
STONE LaFAVEA & SHEKLETSKI
By
ELIZABFH B ON Attorney at Law
Supreme our ID # 60251
414 Br' ge tr et, P.O. Box E
New,Cumber a/?d, PA 17070
Telephone 719-774-7435
Attorneys for Plaintiff
-2-
WILLIAM R. CHENOWETH, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-7576 CIVIL TERM
HOLLY E. HIGGINS CHENOWETH, : CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
) SS:
COUNTY OF CUMBERLAND )
I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys
for the plaintiff hereby certify that I served the Complaint in
Divorce in the above captioned matter on the defendant, Holly E.
Higgins Chenoweth, at 1101 #1 Columbus Avenue, Lemoyne, PA 17043, by
United States Certified Mail, postage prepaid, restricted delivery, on
December 24, 1999, as evidenced by the attached Certified Mail return
receipts.
SWORN TO AND SUBSCRIBED
befo e me this day
of ,tue.r? 1999.
Not y Public
tJOTARIAL SEAL
KAY[ R. LUCKEY, Nolary Public
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ot use for Intematlonal Mail See reverse
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