HomeMy WebLinkAbout09-2678JON SIMPSON,
vs.
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
No. Oq- c2lo'18 Civil Term
SHARON J. WHIPKEY,
Defendant
ACTION 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.
Where 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 at the Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St.
Carlisle, Pa. 17013
(717) 249-3166
L
JON SIMPSON,
vs.
: IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
SHARON J. WHIPKEY,
Defendant
No. 09- 2 t,7 V Civil Term
ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Jon Simpson, a competent adult individual, who resides at 1075-3
Lancaster Blvd., Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Defendant is Sharon J. Whipkey, a competent adult individual, who resides at
56 W. North St., Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
for at least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on November 4, 1989 in
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. 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.
7. Plaintiff and Defendant have no children together.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the
United States of America or any of its allies.
10. The Plaintiff avers that the'grounds on which this action is based are: That
the marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
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. §4904 relating to unsworn falsification to authorities.
J pson, Plaintiff
Respectfully submitted,
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J ne Adams, Esquire
I . No. 79465
7 7 West South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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JON SIMPSON,
vs.
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
SHARON J. WHIPKEY,
Defendant
No. 01 --O?(orj? Civil Term
ACTION IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this May 14, 2009, I, Jane Adams, Esquire, hereby certify that on
May 8, 2009, a certified true copy of the NOTICE TO DEFEND AND DIVORCE
COMPLAINT were served upon the following person, via certified mail, return receipt
requested at the following address:
Sharon J. Whipkey
56 W. North St.
Carlisle, Pa. 17013
DEFENDANT
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Respectfully Submitted:
J" a NAdams, Esquire
7o.79465
West South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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