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YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND
AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST
TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND
NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE
PERSONALLY OR BY AN ATTORNEY AND FILING IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE
MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY
MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR
RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR
PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT. HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE
TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
COMPLAINT FOR DIVORCE
COURT OF COMMON PLEAS, Cumberland COUNTY, PENNSYLVANIA
In re: the Marriage of )
04- G1Sz 7 Z ,
Paul Matthew Wargo ) Docket No.
Plaintiff )
and )
Charlene Ann Wargo )
Defendant )
The Plaintiff, Paul M. Wargo respectfully declares the following:
1. Plaintiffs Residence: Plaintiff resides at 14 Edgewood Drive, Mechanicsburg, PA 17055 and has
been a resident of the Commonwealth of Pennsylvania 51 years, 6 months.
2. Defendant's Residence: Defendant resides at 71 Willow Mill Park Road, Mechanicsburg, PA 17055
and has been a resident of the Commonwealth of Pennsylvania for 58 years.
3. Marriage: On September 20, 1980, in Lyndora, Butler county, Pennsylvania, the Plaintiff and Defendant
married. An official copy of the marriage license is attached to this COMPLAINT FOR DIVORCE.
4. Jurisdiction: This Court is that of proper jurisdiction to hear this cause. The Defendant has agreed to file
an Affidavit of Consent in this cause. Neither the Plaintiff or Defendant has been involved in any litigation or
other proceeding involving the other party in this or any other jurisdiction with respect to their marriage or
any other domestic matter.
5. Grounds for No-Fault: Plaintiff wishes a dissolution of marriage with Defendant based on the following
grounds:
irretrievable breakdown of the marriage with the spouses living separate and apart without cohabitation for
two years.
[Note: This paragraph must describe sufficient legal basis for divorce as recognized by the laws of the
Commonwealth of Pennsylvania. Sufficient basis for a no-fault divorce within Pennsylvania is limited to the
following: (1) irretrievable breakdown of the marriage with the spouses living separate and apart without
cohabitation for two years, or (2) irretrievable breakdown of the marriage, and the spouses have both filed
affidavits that they consent to the divorce. (Note: The court may delay the case for 90 to 120 days if it
appears that a reasonable chance exists for reconciliation. Additionally, 90 days must elapse after the filing
for divorce before the court will grant the divorce.)
6. Marital Settlement Agreement: Plaintiff and Defendant have (copy attached)
X have not entered into a Marital Settlement Agreement.
7. Other Declarations:
No other declarations by plaintiff.
NOW, THEREFORE, Plaintiff requests that the court order a DECREE OF DIVORCE and such further relief
as Plaintiff may have requested herein.
Verification
I, Paul Matthew Wargo, affirm under penalty of perjury that I am the Petitioner in the foregoing COMPLAINT
FOR DIVORCE and that all statements in this Petition are accurate to the best of my knowledge. I have filed
this Complaint in good faith and have not colluded with anyone in relation to it.
0 Pe ' ' ur
14 Edgewood Drive
Mechanicsburg, PA 17055
Subscribed and sworn to before me on this \0 day of 20n.
Nota
COMMONWEALTH OF PENNSYLVANIA
LNotarial Seal
Jr N. Grove, N&Iry Public
Si wp., Curnbadand County
2
My ission ExpirFa Jan. 18,201
Member, Pennsylv- ants Association of Notaries
September 10, 2009
Date
FILEG--COYFIt E
OF THE PR(VITICINMARY
2009 SEP 10 PM 2: 4 7
:,'JUNK'Y
FENN,` Y VANIA.
MARRIAGE CERTIFICATE
License Number: D-11-119
I, FATHER JOSEPH WAR GO
hereby certify that
on September 20, 1980 at LYNDORA PA
PAUL MATTHEW WARGO and CHARLENE ANN SMITH
were by me united in marriage, in accordance with license issued by the Clerk of the
Orphans' Court Division of the Court of Common Pleas of Dauphin County, Pennsylvania.
Certified from the record
June 1. 2009
?X/A 74 4 z o. Clerk of the Orphans' Court Division
FATHER JOSEPH WARGO
Officiant