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Home My WebLink About08-3308/? STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF WILLIAM E. MORROW, Plaintiff V. CHRISTINE E. MORROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 08 - 330 Q CIVIL TERM : 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 S STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF WILLIAM E. MORROW, Plaintiff v. CHRISTINE E. MORROW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO.08 - 3307 CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is William E. Morrow, an adult individual residing at 317 E. Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Christine E. Morrow, an adult individual residing at 40 Marsh Drive, Carlisle, Cumberland County, Pennsylvania 17015. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on April 15, 1967, in Carlisle, 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. f . , ... 6. The plaintiff avers that he has been advised of the availability of counseling and that said party 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 parties and for such further relief as this Honorable Court may deem equitable and just. 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 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. MAW ? / , 2008 William E. orroaw,.P I a i n t iff WOLF & WOLF , 2008 BY: STACY B. LF, ESQUIRE Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff it ? t=' ? P:3 j _ : t ? STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF WILLIAM E. MORROW, Plaintiff V. CHRISTINE E. MORROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 08 - 3308 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. I 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. P" / ., 2008 illiam E. Morrow, Plaintiff N 3a_ co }?- f STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF WILLIAM E. MORROW, Plaintiff V. CHRISTINE E. MORROW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - 3308 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVI E OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 NOW, William E. Mon-ow, being duly sworn according to law, does depose and state: 1. That he is a competent adult. 2. That he served a certified copy of the complaint in divorce upon the defendant on October 5, 2008, by handing the copy of the complaint to the defendant. 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 unworn falsification to authorities. r??? „LDD$ 2008 WILLIAM E. MORROW Plaintiff C-j loavid 1D. Buell Prothonotary XirkS. Sohonage, ESQ Solicitor &nee X Simpson 1" Deputy Prothonotary Irene E. Morrow 2nd Deputy Prothonotary Office of the tothonotary Cumberland County, (Pennsylvania n -33693 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P 230.2 BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 e Carlisle, PA 17013 • (717 240-6195 • Fax(717 240-6573