HomeMy WebLinkAbout01-2880 In the Court of Common Pleas of Cumberland County,
Pennsylvania
BONNIE F. THARP, )
Plaintiff, )
vs. )
)
JAMES W. THARP, ) CIVIL TERM
Defendant. ) 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 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 at:
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.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
In the Court of Common Pleas of Cumberland County,
Pennsylvania
BONNIE F. THARP, )
Plaintiff, )
vs. ) No. 2001 - ~? ~ ~0
JAMES W. THARP, ) CIVIL TERM
Defendant. ) IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in divorce proceeding filed in the
Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance
with Section 3302(d) of the Divorce Code, you may request that the court require you and your
spouse to a~tand marriage counseling prior to a divorce being handed down by the court. A list
of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions arc to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
Michael $. Travis
ID No. 77399
4076 Market Street. Suite 209
Camp Hill. PA 17011
(717) 731-95092
In the Court of Common Pleas of Cumberland County,
Pennsylvania
BONNIE F. THARP, )
Plaintiff, )
vs. ) No. 2001 - .3 ~'~0
)
JAMES W. THARP, ) CIVIL TERM
Defendant. ) IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF TIIE DIVORCE CODE IN DIVORCE
Plaintiff, by her attorney Michael S. Travis, respectfully represents:
1. Plaintiff is Bonnie F. Tharp, who resides at 1640 Main Street Lisburn,
Mechanicsburg, Cumberland County, Pennsylvania, 17055, since 1981.
2. Defendant is James W. Tharp, who resides at 34 E. Dewart Street, Shamokin,
Northumberland County, Pennsylvania, 17872, since "~~ ,R 3.~ o~ ~
3. Plaintiffhas been a bona fide resident of the Commonwealth of P~nnsylvania
for at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on June 21, 1980, in the Country of
Dauphin.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The parties have been living separate and apart. At a subsequent time, plaintiff
may submit an Affidavit that the parties have lived separate and apart for at least two (2) years.
8. Plaintiffhas been advised that counseling is available and that plaintiff may have
thc right to request that the court require the panics to participate in counseling.
....... :- +he Military Service in the United States
9. Netther plamn . . ~.~:. ,~ ~mvi i ns of~e Soldiers' ~d
A~ed Se~ices. Neither plamtlll nth dctentl~t ~ wmm, .... r.___s o
Sailors' Relief Act of Congress ol' 1040 and its men~ents.
10. Plaintiff requests the court to enter a decree of divome.
I vefi~ t~t the statements made in ~is Complaint ~ ~e ~d co,ct. I ~derstmd ~at
fal~ stat~ts here~ are made subject to ~e penalties of 18 Pa. C.S. ~ 4904, ~hting to
~swom fflsification to authorities-
Plaintiff
Allomey t-or t, laintiff
I.D. # 77399
40'/6 Market Street, Suite 209
Camp Hill, PA 17011
(717) 731-9502
Fax 731-9511
MICHAEL S. TRAVI$
ATTORNEy AT LAW
4076 MARKET eITREET, 5UIT£ 209
f'AMp HILL, PA 17011
TI~L£PHONE (717) 7al.aS(~ '.~
In the Court of Common Pleas of Cumberland County,
Pennsylvania
BONNIE F. THARP, )
Plaintiff, )
vs. ) No. 2001-2880
)
JAMES W. TILARP, ) CIVIL TERM
Defendant. ) IN DIVORCE
PRAECIPE TO WITHDRAW COMPLAINT
TO THE PROTHONOTARY:
Please withdraw the complaint in divorce filed by plaintiff in the above captioned mai~er.
Attorney for Plaintiff
4076 Market Street, Suite 209
Camp Hill, PA 17011
I hereby certify that the foregoing is a true and correct statement of the above-captioned
case. This statement is made subject to the penalties of 18 Pa. Cons. Stat. §4904 relating to
unsworn falsification to authorities.
Date: t,~/~t. ~d/ ,aa.e-/ ~
Bonnie F. That'p, Plaintiff
CERTIFICATE OF SERVICE
I, Michael S. Travis, certify that I have this day served a tree and correct copy of the
foregoing document by first class mail, postage prepaid, on the following person, addressed as
follows:
James W. Tharp
34 E. Dewart Street
Shamokin, PA 17872
Dated:,~/~/~/ ~. "ravis
ID No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717)731-9502
Fax 731-9511
Attorney for Plaintiff