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HomeMy WebLinkAbout05-2478 . ... vs. : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY, PENNSYLVANIA :-~ d..t..fT[ : No. {)-5 Civil Term SHERI S. WOOLCOCK, Plaintiff LEONARD M. WOOLCOCK, Defendant : 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. Dauphin County Lawyer Referral Service 213 N. Front Street Harrisburg, Pa. 1710 1 (717) 232-7536 SHERI S. WOOLCOCK, Plaintiff vs. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYL VANIA No. (J.5. .:P-'-I?'Y Civil Term LEONARD M. WOOLCOCK, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE I. Plaintiff is Sheri S. Woolcock, a competent adult individual, who has resided at 2332 Forest Hills Drive, Harrisburg, Pennsylvania, 17112, since 2000. 2. Defendant is Leonard M. Woolcock, a competent adult individual, who has resided at 253 Beacon Dr., Harrisburg, Pa. 17112, since October 1,2004. 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 June 5, 1982 in Greencastle, 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 two children together. 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 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. 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. S4904 relating to unsworn falsification to authorities. Date: S . I 2- . 0 S- ams, sqUIre LD. 0.79465 64 outh Pitt Street arlisle, Pa. 170 IJ (717) 245-8508 ATTORNEY FOR PLAINTIFF ~\'\ - ~ ~ c -t: ~j, ~ ~ ~ -- ~ :ss ~ o :t.. ..... V, Q o c; , ( . C'.'- -f ~ ..... r~' e--' en ~'r __L'" ~: C) -1'"\ ~, ...,._~ ?\'1-'~ "___f"n .';1, r-'j jt ;~~ ~ c.,J --:::l ~.," ~ ,".. ~2 ()'1 c.,J SHERI S. WOOLCOCK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 0 !J-- ~ Lf7 3' Civil Term LEONARD M. WOOLCOCK, : ACTION IN DIVORCE Defendant PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned case discontinued and ended, with prejudice. ""'. (p( /6 B ams, Esquire .D. o. 79465 64 outh Pitt Street arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF Q ...., C) C-=:J (;;::;;) -.0 '._~ en c_ ~ c:: I N ~ r:y Cl ~