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PATRICK F. LAllER, JR
Atlorne~ .. I.."
llUM Ma,"c' SUe.:1
A/lc," lIulldinH
Clmr 'loll. 1',\ 171111
(717) 7IoI."UII
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II NOTICB
I You have been sued in court. If you wish to defend against
,I the claims set forth in the following pages, you must take prompt
II action. You are warned that if you fail to do so, the case may
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I proceed without you and a decree of divorce or annulment may be
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SHARON Y: DARWICHE, . IN THE COURT OF COMMON PLEAS OF
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Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
. No.Cf4 - 1(,1!;
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v. : CIVIL .-_. l-t'rM
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AHMED D. DARWICHE, . CIVIL ACTION - LAW
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Defendant . IN DIVORCE
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entered against you for any claim or relief requested in these
!I papers by the Plaintiff.
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You may lose money or property or other
rights important to you.
When
the
grounds
for
divorce
is
indignities
the
Ii irretrievable breakdown of the marriage, you may request marriage
,
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: i counseling.
A list of marriage counselors is available in the
I
,I Office of the Prothonotary at the Cumberland County Courthouse,
"
'i Carlisle, Pennsylvania
Ii
Ii IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, .
:1 LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, ,
i
II YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
,
,I YOO SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB. IF YOU DO!
'I NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TBB.
OFFICB SBT FORTH BELOW TO FIND OUT WHERE YOU CAN GBT LEGAL HELP. .
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOOSE
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
(717) 240-6200
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SHARON Y'; DARWICHE, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v. . NO. CIVIL 1994
.
I
AHMED D. DARWICHE, I CIVIL ACTION - LAW
Defendant I IN DIVORCE
COMPLAINT IN DIVORCE UNDER 3301 ICI AND 3301 IDI
AND NOW, comes the above-named Plaintiff, Sharon Y. Darwiche,
by and through her nttorneys, The Law Officeo of Patrick F. Lauer,
Jr., Jerry W. Brown, Esquire, and makes the following Complaint in
Divorce I
1. The Plaintiff, Sharon Darwiche, is an adult individual who
currently resides at 100 Darr Avenue, Carlisle, Cumberland County,
Pennsylvania.
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II who currently resides at 100 Darr Avenue, Carlisle, Cumberland
2. The Defendant, Ahmed D. Darwiche, is an adult individual
County, Pennsylvania.
3. The Plaintiff and the Defendant have been residents of the
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I Commonwealth of Pennsylvania for et least six months immediately
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prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on December
29,
in Marysville,
1986
Perry County,
Pennsylvania and were
separated on January 1, 1994.
5. There has never been a prior action of divorce or annulment
:i between the parties.
6. There are two (2) children by this marriage, namely, Tarah
I Marie Darwiche, born July 26, 1989, and Chad Elliott, born February
10, 1987.
7. The grounds for the divorce are as follows I
f.
.
.
a I . The' marriage
in
irretrievably broken;
is
or,
alternative,
bl. Defendant has suffered such indignities to the person of
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,I the Plaintiff, the innocent and injured spouse, so as to render
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her condition intolerable and her life burdensome.
8. The Plaintiff has been advised of the availability of
request that the Court require the parties to participate in i
counseling.
WHEREFORE, the Plaintiff requests this Honorable Court
,I enter a Decree of Divorce in this matter pursuant to 3301(al,
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3301 (cl or 3301 (dl of the Divorce Code.
COUNT II - EQUITABLE DISTRIBUTION
I; 9. Paragraphs one (11 through eight (81 are incorporated
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Ii herein by reference thereto.
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I divide, distribute or assign the marital property between the
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10.
Plaintiff requests Your Honorable Court to equitably
parties without regard to marital misconduct in such proportion as
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the Court deems just after consideration of all relevant factors.
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WHEREFORE, Plaintiff respectfully requests the Court to enter
an Order of Equitable Distribution of marital property pursuant to
23 Paw C.S.A. 3502 (cl of the Divorce Code.
Respectfully submitted:
DATE:
J f~)ll(
W. Brown, Esquire
Market Street
CHill, PA 17011
(7171 763-1800
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VERIFICATION
I, ~ ~ v.w-~V\
;::1 AT~~
Yr Id/-hrw.o.l-.. , state that I am the
the facts set forth
in the above-caPtion~ase
in the above C~~/^'
and that
are true and correct to the best of my knowledge, information and
belief. I realize that false statements herein are subject to
the penalties for unsworn falsification to authorities under 18
Pa. C.S. 4904.
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Date: 3/CJ.. "6 /91