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JOHN F. KING LAW, P.C.
John F. King, Esquire
ID #61919
19 S. Hanover Street
Suite 103
Carlisle, PA 17013
Tel.: (717) 258-4343 /Fax: (717) 422-5526
Attorney for Plaintiff
HOLLY BROOKS
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
TIMOTHY G. BROOKS
Defendant
CIVIL ACTION -LAW
DIVORCE/CUSTODY
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 the 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, PA.
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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
r
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
Respectfully submitted,
JOHN F. KING LAW, P.C.
By: {~,,~... ~--
Jo F. King, Esquire
19 S. Hanover St., Suite 103
Carlisle, PA 17013
JOHN F. KING LAW, P.C.
John F. King, Esquire
ID #61919
19 S. Hanover Street
Suite 103
Carlisle, PA 17013
Tel.: (717) 258-4343 /Fax: (717) 422-5526
Attorney for Plaintiff
HOLLY BROOKS
Plaintiff
v.
TIMOTHY G. BROOKS
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0 9- v~'L o ~.I j ~--
CIVIL ACTION -LAW
DIVORCE/CUSTODY
COMPLAINT UNDER SECTION 3301fc1 OR SECTION 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Holly Brooks, who currently resides at 902 Nixon Drive,
Mechanicsburg, Cumberland County, PA 17055, since May 2008.
2. Defendant is Timothy G. Brooks, who currently resides at 902 Nixon Drive,
Mechanicsburg, Cumberland County, PA 17055, since May 2008.
3. The parties have been bona fide residents in the Commonwealth for at least six (6)
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 24, 2004, in Harrisburg,
Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the Court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
Dated: January , 2009
Respectfully submitted,
JOHN F. KING LAW, P.C.
J F. King, Esquire `
19 S. Hanover St., Suite 103
Carlisle, PA 17013
(717) 258-4343
(717) 422-5526 FAX
John a~johnfkin~law.com
VERIFICATION
I, Holly Brooks, hereby acknowledge that I am the Plaintiff in the foregoing action; that I
have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to
the best of my knowledge, information and belief.
I understand that any false statements herein are made subject to penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
Holly Bro s
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Dated: / / Z ,Y /()
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