HomeMy WebLinkAbout01-2076 SHELLEY E. MARKWOOD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff .
: CUMBERLAND COUNTY, PENNSYLVANIA
v. : CIVIL ACTION- LAW
: 2001 CIVIL TERM
BRIAN K. MARKWOOD, :
Defendant : 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 fights 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
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
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SHELLEY E. MARKWOOD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff ·
: CUMBERLAND COUNTY, PENNSYLVANIA
v. ' CIVIL ACTION- LAW
· 2001- ~'?~ CIVIL TERM
BRIAN IC MARKWOOD, ·
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE .PURSUANT T._0.O SECTION 3301(¢)
O._~F .TI~ plVORCE CODE
NOW comes the plaintiff, Shelley E. Markwood, by her attorney, Mark D. Schwartz, Esquire,
and files this complaint in divorce against the defendant, Brian K. Markwood, representing as follows:
1. The plaintiff is Shelley E. Markwood, an adult individual residing at 215 West Springville
Road, Boiling Springs, Cumberland County, Pennsylvania 17007.
2. The defendant is Brian K. Markwood, an adult individual residing at 505 Spring Run Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
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 August 7, 1999 in Boiling Springs,
Cumberland County, Pennsylvania and separated on March 23, 2001.
5. There have been no prior actions of divorce or for annulment between the parties.
6. There were no children bom to this marriage.
7. Pursuant to the Divome 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 fight to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two
parties.
Respectfully submitted,
IRWIN, cKNI & HUGHES
By: _ . _
Mark D. Schwartz, Esquire,
Attorney for Plaintiff, Shelley E. Markwood
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(7 7) a4 -a s
Supreme Court I.D. No. 70216
Date: April 3rd _, 2001
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.
S-H~LEY E. MARKWOOD -
Date: April 3rd _, 2001
SHELLEY E. MARKWOOD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :
: CUMBERLAND COUNTY, PENNSYLVANIA
v. : CIVIL ACTION- LAW
: 2001- .2t~. CIVIL TERM
BRIAN K. MARKWOOD, :
Defendant · IN DIVORCE
The plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affida~t are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: April 3r.___~__d, 2001
SHELLEY E. MARKWOOD, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
· CIVIL ACTION - LAW
: 2001-2076 CIVIL TERM
BRIAN lC MARKWOOD, IN DIVORCE
Defendant :
ACCEPTANCE OF SERVICE
I, Brian K. Markwood, the defendant in the above-captioned divorce action, hereby verify
that I accepted service of the Complaint in Divorce filed under Section 3301(c) of the Divorce
Code on April 9, 2001.
MAgKWOOO
Date: April 17ch , 2001