HomeMy WebLinkAbout01-0230HEIDI M. WARNER,
Plaintiff
JEFFREY B. WARNER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
..
: CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
2001- ~.30 CIVIL TERM
:
IN DIVORCE
NOTICE
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 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, Carlisle, Pennsylvania 17013.
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, Pennsylvania 17013
717-249-3166
1-800-990-9108
HEIDI M. WARNER,
Plaintiff
JEFFREY B. WARNER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2001-.?~O CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the plaintiff, Heidi M. Warner, by her attorneys, Irwin, McKnight &
Hughes, Esquire, and files this Complaint in Divorce against the Defendant, Jeffrey B. Warner,
upon the cause of action hereinafter set forth:
1. The Plaintiff is Heidi M. Warner, an adult individual residing at 51 Blue Pond Road,
Newville, Cumberland County, Pennsylvania 17241.
2. The Defendant is Jeffrey B. Warner, an adult individual residing at 1840 Pine Road,
Newville, Cumberland County, Pennsylvania 17241.
3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on November 18, 1989, in Carlisle,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. There were three (3) children bom to this marriage, namely Zackary B. Warner, bom
August 30, 1990, age ten (10) years; Jeffrey N. Warner, bom September 3, 1992, age eight (8)
years; and Gregory S. Warner, bom August 9, 1995, age five (5) years.
7. Pursuant to the Divorce Code, Section 3301(c), the Plaintiff avers as the grounds
upon which this action is based that the marriage between the parties is irretrievably broken.
8. The Plaintiff avers that she has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the Plaintiff demands judgment dissolving the marriage between the
two parties.
Date: January 8, 2001
Respectfully submitted,
I~M~KN~.C~T & HUGHES
Attorney for Plaintiff
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 70216
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel and me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unswom falsification to authorities.
DIM. WARNER
Date: January 8, 2001