HomeMy WebLinkAbout09-8553MCNEES WALLACE & NURICK LLC
By: J. Paul Helvy
Attorney I.D. No. 53148
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 237-5343
(717) 260-1701 (fax)
Email: phelvy@mwn.com
ELIZABETH STANLEY-SWOPE,
Plaintiff
V.
EDWARD P. SWOPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. OQ - 8553 CIVIL TERM
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 of divorce or
annulment may 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 at the Cumberland County Courthouse,
Carlisle, PA.
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
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
•
ELIZABETH STANLEY-SWOPE,
Plaintiff
V.
EDWARD P. SWOPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0'?- Y S3 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT
And now comes Plaintiff, Elizabeth Stanley-Swope, by and through her counsel,
McNees Wallace & Nurick LLC, and files the following Complaint in this matter.
COUNTI
Divorce Under 3301(c) and (d) of the Divorce Code
1. Plaintiff is Elizabeth Stanley-Swope who currently resides at 486 Nursery
Drive South, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant is Edward P. Swope who currently resides at 929 Woodridge
Drive, Enola, Cumberland County, Pennsylvania 17025.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months previous to the filing of this
Complaint.
4. Plaintiff and Defendant were married on February 20, 1982, in Lebanon,
Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the
United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act
of the Congress of 1940 and its amendments.
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6. There have been no prior actions of divorce or for annulment between the
parties.
7. The marriage is irretrievably broken.
8. The grounds on which the action for divorce is based are:
A. Section 3301(c): The marriage of the parties is irretrievably broken.
After 90 days have elapsed from the filing of this Complaint, it is believed the parties will
file Affidavits of Consent to a divorce.
B. Section 3301(d): The marriage of the parties is irretrievably
broken. After two years from the date of separation, Plaintiff intends to file an Affidavit
alleging that the parties have lived separate and apart for a period of two years and that
the marriage is irretrievably broken, and she anticipates that Defendant will not deny
that the parties have been separated for a period of at least two years and that the
marriage is irretrievably broken.
9. Plaintiff has been advised of the availability of counseling and that she
may have the right to request that the Court require the parties to participate in
counseling. Plaintiff hereby waives his right to such counseling.
10. Plaintiff requests the court to enter a decree of divorce.
-3-
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under
Section 3301(c) and (d) of the Divorce Code.
McNEES WALLACE & NURICK LLC
By
J. Pa elvy
Attofnev. I . D. 148
Attorneys for Plaintiff
Dated: December 10, 2009
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0 0
VERIFICATION
Subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities, I hereby certify that the facts set forth in the foregoing document are true and
correct to the best of my information and belief.
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Eliz eth Stanley.Swope
Dated:
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