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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 '6` (A (? N Q 00 G- r w.Yb ? r 'V 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) ?" ? yr' " • S ? e} 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 li c C-i Buerr Trothonotaly - - ��~�/�°���-+n�x 0� �[�� �� /u�/l��C()°^^, ~°" � Cum6errand/ounbl , annsykania -^-rk''~——o`--Q. 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