HomeMy WebLinkAbout15-0299 L.
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HAROLD S.IRWIN,111,ESQUIRE
ATTORNEY ID NO.29920 ZJ �? 16 Ali 11: l}S
64 SOUTH PITT STREET
CARLISLE PA 17013 f121"ISERLAi' D COUNTY
(717)319.7560 PENNSYLVANIA
ATTORNEY FOR PLAINTIFF
THOMAS P. NEALY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V0 : CIVIL ACTION - LAW
: NO. 2014g002)9Ct`CIVIL TERM
MEOA'N C. NEALY,
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 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-2493166
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THOMAS P. NEALY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :,CIVIL ACTION LAW
NO. 2014- CIVIL TERM
MEGAN C. NEALY, :
Defendant : IN ,DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c)
OF THE 'DIVO'RCE CODE
NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in
divorce against the defendant, representing as follows:
1. The plaintiff is THOMAS P. NEALY, an adult individual residing at 870 Shippensburg
Road, Newville, Cumberland County, Pennsylvania 17241.
2. The defendant is MEGAN C. NEALY, an adult individual residing at 14 North High
Street, Newville, Cumberland County, Pennsylvania 17241.
3. The parties have been residents of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce.
4. The parties were married on September 26, 2009, in Newville, Pennsylvania.
5. 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.
6. The plaintiff avers that he has been advised of the availability of counseling and that he
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 parties.
a-
I verify that the facts contained herein 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.
January 2015
THOMAS P. NEAI_Y, Plaintiff
HAROLD S. IRWIN, III
Attorney for Plaintiff
64 South Pitt Street
Carlisle, Pennsylvania 17013
(717) 319-7560
Supreme Court ID No. 29920
THOMAS P. NEALY, : IN THE COURT OF COMMON 'PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
V. : CIVIL ACTION - LAW
: NO. 2014- CIVIL TERM
MEGAN C. NEALY, :
Defendant : IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFI!D"IT
The plaintiff, being duly sworn according to law, deposes and says:
1. 1 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. 1 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.
verify that the statements made in this affidavit 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.
January 2015
THOMAS P. NEALY, Plaintiff