HomeMy WebLinkAbout09-7091P. Richard Wagner, Esquire
PA Supreme Court I.D. #23103
Mancke, Wagner, Spreha & McQuillan
2233 North Front Street
Harrisburg, PA 17110
Telephone (717) 234-7051
Fax (717) 234-7080
Attorney For Plaintiff
CHARLES R. AGNEW, : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. NO:-7091 0- +vil-hM
ANNE AGNEW,
Defendant.
: CIVIL ACTION - LAW
: 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 in divorce or annulment may be entered against you by the Court. A
judgment may also be entered against you for another 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, 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 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
2 LIBERTY AVENUE
Carlisle, PA 17013
(717) 249-3166
P. Richard Wagner, Esquire
PA Supreme Court I.D. #23103
Mancke, Wagner, & Spreha
2233 North Front Street
Harrisburg, PA 17110
Telephone (717) 234-7051
Fax (717) 234-7080
Attorney For Plaintiff
CHARLES R. AGNEW,
Plaintiff,
V.
ANNE AGNEW,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: Qq, 109/ Cc - -rzt '
CIVIL ACTION - LAW
IN DIVORCE
AND NOW, comes the Plaintiff, by and through his attorneys, Mancke, Wagner &
Spreha, and files the following Complaint in Divorce:
1. The Plaintiff Charles R. Agnew, is an adult individual residing at 4235 Sussex Drive,
Apt. #39, Harrisburg, Dauphin County, Pennsylvania.
2. The Defendant, Anne Agnew, is an adult individual residing at 14 S. Madder Drive,
Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months prior to the filing of this Complaint.
4. Plaintiff and Defendant are husband and wife having been married on June 24, 1978,
in North Huntingdon, West Moreland County, Pennsylvania.
5. There were two (2) children born unto the marriage, both of majority age.
6. There have been no prior actions of divorce or annulment between the parties in this or
any other jurisdiction.
7. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States
or any of its Allies.
8. Plaintiff has been advised of the availability of counseling and that he has the right to
request that both parties participate in counseling.
9. Plaintiff avers as grounds on which this action is based are:
A. That the marriage is irretrievably broken pursuant to the provisions of
§3301(c) of the Divorce Code;
B. That as of August 21, 2011, the parties will have lived separate and apart
for a period of at least two (2) continuous years pursuant to §3301(d) of
the Divorce Code.
WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce.
COUNTI
EQUITABLE DISTRIBUTION
10. Paragraphs 1 through 8 above are incorporated herein by reference and made a part
hereof.
11. During the marriage, Plaintiff and Defendant have acquired various items of marital
property, both real and personal, which are subject to equitable distribution under Section 401 of
the Divorce Code of 1980.
-2-
WHEREFORE, Plaintiff prays this Honorable Court:
(a) Enter a Decree in Divorce; and
(b) Equitably distribute all property, both real and personal, owned by
the parties.
Respectfully submitted,
Mancke, Wagner & Spreha
P. and Wagner, Esquire
.D.#23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Plaintiff
Date: / ??6 y
?T
-3-
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A.
relating to unsworn falsification to authorities.
Date:
F / V
FILFU-OF CE
OF THE PSI T:-'I `'N,.1CTARY
2004 OOT 15 Ph 3: 06
$3W.5o PO A`i TY
CO 5553
asaI i'7 a
cDavid D. Bueff
Prothonotary
xirkS. Sohonage, :ESQ
Soricitor
Renee X Simpson
151 Deputy Prothonotary
Irene E. 3forrow
2nd Deputy Prothonotary
Office of the Prothonotary
Cumberfand County, Pennsy(vania
109ft CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 30TH DAY OF OCTOBER, 2012, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P. 230.2.
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY