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iANE ADAMS
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ATTORNEY AT LAW
Attorney I.D. No. 79465
17 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
esc~adams@~mail.com
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ROBERT E. COLLINS,
Plaintiff
vs.
LORI L. COLLINS,
Defendant
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. /O -- 3 ~~~ Civil Term
ACTION 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.
Where 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 at the Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 South Bedford St.
Carlisle, Pa. 17013
(717) 249-3166
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SANE ADAMS
ATTORNEY AT LAW
Attorney I.D. No. 79465
17 W. South St.
Carlisle, Pa. 17013
(717) 245-8508
esc~adams@gmail.com
ROBERT E. COLLINS,
Plaintiff
vs.
LORI L. COLLINS,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. Civil Term
ACTION IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I -DIVORCE
1. Plaintiff is Robert E. Collins, a competent adult individual, who resides at 183
Woods Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
2. Defendant is Lori L. Collins, a competent adult individual, who resides at 14
Amherst Drive, Camp Hill, Cumberland County, Pennsylvania, 17011.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
for at least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on April 30, 1988 in
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. Plaintiff has been advised that counseling is available and that plaintiff may
have the right to request that the court require the parties to participate in counseling.
7. Plaintiff and Defendant have one child together, however he is an adult
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the
United States of America or any of its allies.
10. The Plaintiff avers that the grounds on which this action is based are: That
the marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
COUNT II -EQUITABLE DISTRIBUTION OF PROPERTY
11. Paragraphs 1 - 14 are herein incorporated by reference.
12. During the course of the marriage, the parties have acquired numerous items
of property, both real and personal, which are held in joint names and in the individual
names of each of the parties hereto.
13. Plaintiff and Defendant have been unable to agree as to an equitable
division of said property.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure
by the Defendant, to equitably divide the property, both real and personal, owned by the
parties hereto as marital property.
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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Robert E. Collins, Plaintiff
Respectfully submitted,
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Date: ,~ ~~ ~~
ne Adams, Esquire
D. No. 79465
7 West South St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
ROBERT E. COLLINS, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 10 - 3353 Civil Term
)
LORI L. COLLINS, : ACTION IN DIVORCE
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Defendant
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STATEMENT OF INTENTION TO PROCEED
TO THE PROTHONOTARY:
Plaintiff, Robert E. Collins, intends to proceed with the above-captioned
matter. Please remove this case from the termination list.
Respectfully Submitted,'
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Date: /61 F, Fe-Adams, Esquire
W. South St.
Carlisle, Pa. 17013.
(717) 245-8508
ATTORNEY FOR PLAINTIFF