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Home My WebLink About07-7138• S e Charlotte A. Inks IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v. NO. 07- ~ /fig' CIVIL TERM Duane G. Inks 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 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, Pennsylvania. 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 t ~ + . Charlotte A. Inks IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA CIVIL TERM Duane G. Inks Defendant IN DIVORCE COMPLAINT UNDER 3301 c or d OF THE DIVORCE CODE 1. Plaintiff is ~ 0.f' `p-~--f-~ f~. L ~(~ who currently resides at 32 ~n.~. ~ Cumberland County, Pennsylvania. ~ v 2. Defendant is ~ G ~: N CGS " ,who currently resides at I~omE, 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ~c ---~' -~, ooh at T.~l' ~.,._ _ _J 5. The marriage is irretrievably broken, and the parties separated on m „r, _ , _ aav5 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of~s/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. ,. r y 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. ---_- ate Plaintiff, Pro Se I, ~11c„-lo~f~ /~. ~Nks verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. ~, /z s/~ ~ Date. r Plaintiff, Pro Se Assisted by: Barbara Sumple-Sullivan, Esq. Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ~ , ~ •i Charlotte A. Inks IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v' N0.07- ~/3~ CIVIL TERM Duane G. Inks Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceedin filed in g the Court of Common Pleas of Cumberland County. This notice is to advise ou y that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court re ' quire you and your spouse to attend marriage counseling prior to a divorce being handed down b the Y 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 ke pt as a convenience to you and you are not bound to choose a counselor from this list. All necessar arrangements and the cost of counseling sessions are to be borne b ou a y Y Y nd your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ~, ~ ~ ~~ ` r-Gi _ r i4 1 ` .r .- C~ ~p .. ~a, ~ _ Charlotte A. Inks IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v' N0.07- ?!3~ CIVIL TERM Duane G. Inks Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Charlotte A. Inks Plaintiff, to proceed in forma au eris. I, Barbara Sumple-Sullivan, attorney for the party proceeding in forma au eris, certif that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Attorney for Plaintiff 1 Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ' ra 0 C_ ~ -~ K ~'~_ '~' ~ ~~ r f k ... t~ ~ i.,.~ _' i_ ~ ~. ~~ ~ '.. - . ~ i ' _- ~ r r+ ~ <~ ~,.. •-~ Charlotte A. Inks IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v. N0.07- 7/3~ CIVIL TERM Duane G. Inks Defendant IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDA VTT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on !Yl p-~c (~ ~~~o ~ live separate and apart for a period of two years. ~ and continued to 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital ro ert lawyer's fees, or expenses if I do not claim them before a Divorce is granted. p p y~ I' ~-~^~-~'' ~• ..~-.'k ~ ,verify that the statements made in true and correct to the best of my knowledge, information, and belief. I understand thatlfase statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. l ~-~ \c~~ Dd~e Plaintiff, Pro Se Charlotte A. Inks IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAIVn COUNTY PEN1VSYLVANIA v. No. 07- Crv~, TERNr Duane G. Inks Defendant : IN DrvORCE COUNTER-AFFIDAVIT UNDER SECTION 3301 d OF THE DIVORCE CODE I • Check either (a) or (b): ^ (a) I do not oppose the entry of a divorce decree. ^ (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ^ (i) The parties to this action have not lived separate and apart for a period of at least two years. ^ (ii) The marriage is not irretrievably broken. 2• Check either (a) or (b): ^ (a) I do not wish to make any claims for economic relief. I understand that I ma Y lose rights concerning alimony, division of property, lawyer's fees or expenses if I do no t claim them before a divorce is granted. ^ (b) I wish to claim economic relief which may include alimony, division of pro ert lawyer's fees or expenses or other important rights. p y~ I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do s 0 before the date set forth on the Notice of Intention to Request Divorce Decree, the divor Ce decree may be entered without further delay. 1 verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 49 § 04 relating to unsworn falsification to authorities. DATE: Duane G. Inks NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORC DECREE AND YOU DO NOT WISH TO MADE ANY CLAIM FOR ECONO E RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. MIC C) ``~' L` ~ ~ Ii ~ ~- ~~ T 'i'1 " ,~ f 17 t~~ - ~ ~] t ,~ ~ ~ ~ ~ _.i. . . ~ . . w ) y_a _,... ~ ~ ~..,,~ ~~~ ^_