HomeMy WebLinkAbout03-6471SUSAN D. SWOPE
Plaintiff
RICHARD C. SWOPE
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERALND COUNTY, PENNSYLVANIA
;
: CIVIL ACTION - LAW
: DIVORCE
: No. t~3 - &qTI i
NOTICE TO DEFEND AND CLAIM RIGHTS
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
the Court may enter a decree of divorce or annulment against you. A judgment may also be
entered against you for any other claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
When the grounds for divome include indignities or irretrievable breakdown of marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, High and Hanover Streets, Carlisle,
Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOOSE THE RIGHT TO 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
(717) 249-3166
SUSAN D. SWOPE
Plaintiff
RICHARD C. SWOPE
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERALND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCE
No. O$ -
COMPLA/NT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. The Plaintiffis Susan D. Swope, an adult individual currently residing at 35
Burnside Drive, East Berlin, Adams County, Pennsylvania 17316.
2. The Defendant is Richard C. Swope, an adult individual currently residing at
3812 Cedar Avenue, Camp Hill, Cumberland County Pennsylvania 17011.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for a period in excess of six (6) months immediately preceding the filing of this
Complaint.
4. Plaintiff and Defendant were married on August 23, 1980 in Harrisburg,
Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. Plaintiff and Defendant separated on or about September 19, 1987.
7. The causes of action and sections of the Divorce Code under which Plalntiffis
proceeding are:
A. Section 3301(c) - the marriage of the parties is irretrievably
broken.
B. Section 3301(d) - the marriage of the parties is irretrievably
broken. The parties separated on or about September 19, 1987.
8. There is one child bom of this marriage, Benjamin M. Swope, over the age of
eighteen and bom on September 8, 1985.
9. This action is not collusive.
10. Plaintiff is not a member of the Armed Services of the United States or any of its
Allies.
11. Plaintiff has been advised of the availability of marriage counseling and that
Plaintiff may have the fight to request that this Honorable Court require the parties to participate
in counseling.
12. Plaintiff does not request that the Court require that she and her spouse participate
in marriage counseling prior to a divorce decree entered by this Honorable Court.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a final
decree in divorce.
Respectfully submitted,
Valerie J. ~ed,-E~qu~re
I.D. # 87442
2807 Market St.
Camp Hill, PA 17011
(717) 920-9460
Attorney for Plaintiff
VERIFICATION
I, SUSAN D. SWOPE, do verify that the facts contained in the foregoing
document are tree and correct to the best of my knowledge, information, and belief. I
understand that false statements are made subject to the penalties of 18 Pa.C.S. ~4904
relating to unswom falsification to authorities.
Date:
SUSAN D. SWOPE
SUSAN D. SWOPE
Plaintiff
RICHARD C. SWOPE
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERALND COUNTY, PENNSYLVANIA
_.
: CIVIL ACTION - LAW
: DIVORCE
..
: No.
CERTIFICATE OF SERVICE
I, Valerie J. Faden, Esquire, attorney for Plaintiff in the above-captioned matter, do
hereby certify that I served a tree and correct copy of the Notice to Defend and Claim Rights and
Complaint Under Section 3301(c) or 3301(d) of the Divorce Code upon the Defendant by
certified mail, return receipt requested and also by depositing s, mae in the U.S. Mail, first class,
postage prepaid, on the [~4day of -~ ~ 2003 addressed as follows:
Richard C. Swope
3812 Cedar Avenue
Camp Hill, PA 17011
By: Valede ~le~, Esquire
I.D. # 87442
2807 Market Street
Camp Hill, PA 17011
(717) 920-9460
Attorney f6r Plaintiff
E625 99E6 0000 0050 E00~
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE Of ~~. PENNA.
SUSAN D. SWOPE
Plaintiff
VERSUS
RICHARD C. SWOPE
Defendant
NO. 03-6471 CIVIL Term
DeCrEE IN
DIVORCE
AND NOW, ~D~', 7 2004
DECREED THAT
SUSAN D. SWOPE
AND RICHARD C. SWOPE
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, It IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH hAVE
BEEN RAISED OF RECORD IN THIS ACTION FOr WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
No claims pendinq
~~4OTARY