HomeMy WebLinkAbout09-2419i ~~
Heather M. Stewart IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
v• N0.09- O~~~y CIVIL TERM
John A. Stewart :
Defendant IN DIVORCE
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 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, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEE5 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 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
Heather M. Stewart IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
v• N0.09- ~ `~/9 CIVIL TERM
John A. Stewart .
Defendant IN DIVORCE
COMPLAINT UNDER &3301(c) or (d) OF THE DIVORCE CODE
1. Plaintiff is /`y~'.~I 6,r2 I~_ S~-fj~~ ,who currently resides at
Cumberland County, Pennsylvania.
2. Defendant is ~~o ~, ,~ ~- , ,~~.~7L ,who currently resides at
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at
least the six months prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on c~ • ~ ~ , X00'7 at
5. The marriage is irretrievably broken, and the parties separated on
6. There have been no prior actions of divorce or annulment between the parties.
7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the
military service of the United States of America, but is in fact living at the address
given in Paragraph 2 above.
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request that the Court require the parties participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
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Date Plaintiff, Pro Se
h /_~~~ /~ ~:.~s ~ verify that the statements made in this Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unsworn falsification to authorities as
provided in 18 Pa. C.S. §4904.
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Date.
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Plaintiff, Pro Se
Assisted by:
Darren J. Holst, Esq.
Howett, Kissinger & Holst, P.C.
130 Walnut St., P.O. Box 810
Harrisburg, PA 17108
(717) 234-2616
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Heather M. Stewart IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
v. N0.09- a~'~ y CIVIL TERM
John A. Stewart
Defendant IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Heather M. Stewart, Plaintiff, to proceed in forma ap uperis.
I, Darren J. Holst, attorney for the party proceeding in forma ap uperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to the
P~Y•
Darren JlHolst, Esquire ~~Si~~
Attorney for Plaintiff
Howett, Kissinger & Holst, P.C.
130 Walnut St., P.O. Box 810
Harrisburg, PA 17108
(717) 234-2616
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