HomeMy WebLinkAbout08-3518HAROLD S. IRWIN,111, ESQUIRE
ATTORNEY ID NO. 29920
64 SOUTH PITT STREET
CARLISLE PA 17018
(717) 24346050
ATTORNEY FOR PLAINTIFF
LINDA HAWK SMITH, : IN THE COURT OF COMMON PLEAS OF
PlalntM : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
NO. 2008 - 3518 CIVIL TERM
GERALD L. BLAIN,
Defendant : 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
LINDA HAWK SMITH,
Plaintiff
v.
GERALD L. BLAIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2008 - 35'/ CIVIL TERM
. IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in
divorce against the defendant, representing as follows:
1. The plaintiff is LINDA HAWK SMITH, an adult individual residing at 14 Back Street,
Plainfield, Cumberland County, Pennsylvania 17081.
2. The defendant is GERALD L. BLAIN, an adult individual residing at 14 Back Street,
Plainfield, Cumberland County, Pennsylvania 17081.
3. The parties 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 February 29, 1992, in Plainfield, 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.
6. The plaintiff avers that he has been advised of the availability of counseling and that she
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.
I verify that the facts contained herein 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.
June 10, 2008)
D HAWK SMI , Plaintiff
HAROLD S. IR IN, III
Attorney for Plaihtiff
64 South Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-6090
Supreme Court ID No. 29920
LINDA HAWK SMITH,
Plaintiff
v.
GERALD L. BLAIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
.NO. 2008 - CIVIL TERM
: IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
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. 1 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.
June 10, 2008 qt,?? , ,-a,
DA HAWK SMITH, Plaintiff
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HAROLD S. IRWIN, 111, ESQUIRE
ATTORNEY ID NO. 29920
"SOUTH PITT STREET
CARLISLE PA 17015
(717) 243.6090
ATTORNEY FOR PLAINTIFF
LINDA HAWK SMITH, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
GERALD L. BLAIN, : NO. 2008 - 5518 CIVIL TERM
Defendant : IN DIVORCE
PRAECIPE TO REINSTATE
Please reinstate the Complaint in the abo a captioned matter.
August 19, 2008
HAROLD S. IRWI III
Attorney for Plaint)
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HAROLD S. IRWIN, 111, ESQUIRE
ATTORNEY 10 NO. 299920
64 SOUTH PITT STREET
CARLISLE PA 17013
(717) 243.6090
ATTORNEY FOR PLAINTIFF
LINDA HAWK SMITH,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2008 - 3518 CIVIL TERM
GERALD L. SLAIN,
Defendant
: IN DIVORCE
PRAECIPE TO REINSTATE
Please reinstate the
in the above captioned matter.
October 2, 2008
HAROLD S IRWIN,
Attorney for Plaint
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SoCicitor
OP - 3578 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TDAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH 'PREJUDICE IN ACCORDANCE WITH
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY