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Thomas D. Gould, Esquire
I.D. # 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
BARBARA JEAN SZCZYPTA,
PLAINTIFF
IN THE COURT OF COLON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANDREW SZCZYPTA,
DEFENDANT
NO. 2009 - CIVIL TERM
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 is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Court Administrator's
Office, Third floor, Cumberland County Courthouse, Hanover and High
Streets, Carlisle, Pennsylvania.
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.
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.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
THOMAS D. GOULD, ESQUIRE
2 EAST MAIN STREET
SHIREMANSTOWN, PA 17011
(717) 731-1461
BARBARA JEAN SZCZYPTA, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2009 - .YX9,2- CIVIL TERM
ANDREW SZCZYPTA, IN DIVORCE
DEFENDANT
COMPLAINT UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
1. The Plaintiff is Barbara Jean Szczpyta who currently
resides at 415 Williams Grove Road, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
2. The Defendant is Andrew Szczypta whose last know address
(Z
was West Main Street, Shiremanstown, Cumberland County,
Pennsylvania 17011.
3. The Plaintiff and Defendant have been bonafide residents
of the Commonwealth of Pennsylvania for at least six months
immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 24, 1996
in Cumberland County, Pennsylvania.
5. There were no children born of this marriage.
6. There have been no prior actions of divorce or annulment
between the parties in this or any other jurisdiction.
7. The marriage is irretrievably broken.
8. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
9. There were no children born of this marriage.
10. The Plaintiff has been advised of the availability of
counseling and that Plaintiff may have the right to request that
the Court require the parties to participate in counseling.
11. Plaintiff requests the court to enter a decree of
divorce.
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Thomas D. Gould
Attorney for Plaintiff
I.D. # 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
VERIFICATION
I 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.
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Date: G f?' v
Barbara Je Szczypta
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JUN TARY,
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