HomeMy WebLinkAbout94-01343
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LOIS B. MORRISON,
Phllntllf
IIN TIlE COURT OF COMMON PLEAS OF
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I CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL ACfION. LAW
l\Jo. CJ4- /3143
NO. CIVII4 1994
c,1V11 THM
ROBERT J. MORWSON,
Derendant
IN DIVORCE
NO'J'I(;E TQ J)t;'I~
You have been sued In court, If you wish to defend against the ClailllS set forth in the
followlnll !1ages, you must take prompt action, You are warned that If you fall to do ao, the caae
may proceed without you and a decree in divorce or annulment may be entered allainst you by the
court. A judgment may also be entered against you for any other claim or relief requested In theae
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 Indignltles or Irretrievable breakdown of the marriage, you
may request marriage counseling. A list of maniag' counselors Is available In the Office of the
Prothonotary, Cumberlan" 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 MA V LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO VOUR LAWVER 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
HtLP.
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Court Administrator
Cumberland County Courthouse Fourth Floor
1 Courthouse Square
Carlisle, Pennsylvania 17013
(717) 2..0.6200
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LOIS B. MOlUUSON,
Plalnllff
I IN THE COURT OF COMMON PLEAS OF
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I CUMBERLAND COUNTY, PENNSYLVANIA
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I CIVIL ACTION. LAW
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, NO. CIVIL 1994
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I IN DIVORCE
v.
ROBERT J. MORRISON,
Derend.nt
l1l.1WlANl' 1'J) SES:TlONS 33011.\(6) ANI,) ~~911d
Ql 1'11.& I,)JVO~CE CODt
AND NOW, comes the Plaintiff and by her attorneys, Irwin, Irwin & McKnlght, Esquires,
Illes this Complaint In Divorce against the Defendant upon the cause of action hereinafter set
forth:
1.
The nllll. of the Plaintiff Is Lois B. Morrison and the name of the Oefendant Is Robert J.
Morrison.
2.
The Plaintiff Is an adult Individual who resides In West Pennsboro Town~hip, Cumberland
County, Pennsylvania; her current address being 464 Cross Road School Road, Carlisle,
Pennsylvania 17013.
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3.
The last known r..ldence and prelent whereabout. of the Defendant I. North Newton
Town.hlp, Cumberland County, Penn.ylvanla; hi. current addre.. belns 522 Sprinsfteld Road,
Shlppen.burlil, Pennlylvanla 17257.
4.
The Plalntltl' and Defendant have re.lded in the Commonwealth of Penn.ylvanla for at
lea.t .Ix months previous to the filing of this action In divorce.
5.
The Plaintiff and Defendant were married on December 9, 1967 in ShlppenlbullJ,
Cumberland County, Pennsylvania 17257.
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6.
Pursuant to the Divorce Code, Section 330 1 (a)(6), the Plaintltl'avers as the ground. upon
which tbis action Is based that the Plaintlft'is the injured spouse and that the Defendant has oWered
such Indignities to her as to render her condition Intolerable and life burdensome.
7.
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The Plaintiff avers that she has been advised of the availability of counseling and that laid
party has the right to request that the court require the parties to participate In counsellns.