HomeMy WebLinkAbout01-5081EDWARD R. SWINGLE,
Plaintiff
BERNADETTE M. DONNELLY,
Defendant
: 1N THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01- fi'Off'/ CIVIL TERM
: CIVIL ACTION - LAW
' 1N 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
will proceed without you and a decree in divorce or annulment may 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 the 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 the First Floor, Cumberland County Courthouse, South Hanover Street,
Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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
EDWARD R. SW1NGLE,
Plaintiff
BERNADETTE M. DONNELLY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-..~ ~'{ CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Edward R. Swingle, an adult individual, currently residing at 420
Market Street, New Cumberland, Cumberland County, Pennsylvania.
2. Defendant is Bernadette M. Donnelly, an adult individual, currently residing at 428
Reno Avenue, New Cumberland, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are bonafide residents of the Commonwealth of
Pennsylvania and have been so for at least six months immediately previous to the filing of this
complaint.
4. Plaintiff' and Defendant were married on June 5, 1999 in York, York County,
Pennsylvania.
5. There have been no prior actions for divorce or annulment between the parties.
6. The Defendant is a member of the Armed Forces of the United States of America,
or its Allies.
7. The Plaintiff has been adx4sed of the availability of counseling and the right to
request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff
does not desire that the Court require the parties to participate in counseling.
8. Plaintiffand Defendant are citizens of the United States of America.
9. The parties have lived separate and apart since July 15, 2001 and continue to live
separate and apart as of the date of this Complaint.
10. The parties' marriage is irretrievably broken.
11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety
days from the date of the filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce.
Respectfully Submitted,
Kirstin M. Sweigard, Esquire
KL1NE LAW OFFICE
714 Bridge Street
Post Office Box 461
New Cumberland, PA 17070-0461
(717) 770-2540
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities.
Date
EDWARD R. SWINGL'~E
EDWARD R. SWINGLE,
Plaintiff
BERNADETTE M. DONNELLY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. oI-CIVIL XEmU
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
I HEREBY CERTIFY THAT I served a certified copy of the Divorce Complaint filed in the
above captioned case upon Defendant, by certified mail, retum receipt requested on August 31,
2001 addressed to:
Bernadette Donnelly
428 Reno Avenue
New Cumberland, PA 17070
and did thereafter receive same as evidenced by the attached Post Office receipt card dated
September 4, 2001.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF
SERVICE 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. SECTION 4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
Date
I4JR~TIN M. SWEIG'A~RD,~gQUIRE
714 Bridge Street
Post Office Box 461
New Cumberland, PA 17070-0461
(717) 770-2540
Attorney for Plaintiff
Postage
Certified Fee
Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement RequiredI
Total Postage & Fees
· Complete items 1, 2, and 3. Aisc complete
item 4 if Restricted Delivery is desired.
· P{int your name and address on the reverse
so that we can return the card to you.
· Attach this ca~o the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
i
Date of Delivery
[] Agent
[] Addressee
Is deliver~ [] Yes
YES, enter delivery address below: [] NO
3. Service Type
.Cer~ified Mail
Registered
[] Insured Mail
[] Express Mail
[] Return Receipt for Merchandise
[] C.O.D.
4, Restricted Delivery? (Extra Fee)
J~'Yes
102595-00-M-0952
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
~, Plaintiff
vs.
Defendan t~:
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
COMMONWEALTH OF PENNSYLVANIA:
:
COUNTY OF CUMBERLAND :
Notice is hereby given that the Plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
~ day of.~~~ .~d~/ · hereby elects to resume the
prior surname of _ A~/7~ ~/L~ , and gives
thzs written not,ce pursuant to ~he provisions of 54 P.S. S 704.
DATE: ~ ~
Signature /
gnature of name being re~~
SS.
On the L/T'~ day of _~'~ · °~'dO'~, before me, a
Notary Public, personally appea'r'~d~e-above affiant known to me to
be the person whose name is subscribed to the,. within document and
acknowledged that he/she executed the foregoing for the purpose
therein contained.
seal.
In Witness Whereof, I have hereunto set my hand and official
NOTARIAL SEAL
JODY S. SMITH, NOTARY PUBLIC
Carlisle Boro, Cumberland County
My Commission Expires April 4, 2005