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OF
OR
OF
EDGAR B, PEARSON,
Plaintiff
v,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO,q/f-J.!fj)- CIVIL ~
I t' nyt
VIENNA M, PEARSON,
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 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,
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 Cumberland
County Court House, High and Hanover Street, Carlisle,
Pennsylvania,
IF YOU DO NOT FILE
PROPERTY, LAWYER'S FEES
ANNULMENT IS GRANTED, YOU
THEM,
A CLAIM FOR
OR EXPENSES
MAY LOSE THE
ALIMONY, DIVISION
BEFORE A DIVORCE
RIGHT TO CLAIM ANY
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 Court Administrator
One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
SAIDIS, GUIDO
& MASl.ANI)
26 W. WgII Street
Carlisle. PA
LAND
By:
Edward Esquire
Supreme # 21206
26 West High Street
Carlisle, PA 17013
(7171 243-6222
Attorney for Plaintiff
EDGAR B, PEARSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO,
CIVIL 199
VIENNA M, PEARSON,
Defendant
IN DIVORCE
COMPLAINT UNDER SECTION 33011c\
OF THE DIVORCE CODE
1, Plaintiff is Edgar B, Pearson, who currently resides
at 1880 Esther Drive, North Middleton Township, Carlisle,
Cumberland County, Pennsylvania,
2, Defendant is vienna M, Pearson, who currently resides
at 1880 Esther Drive, North Middleton Township, Carlisle,
Cumberland County, Pennsylvania,
3, Plaintiff and Defendant have been bona fide residents
in the Commonwealth for at least six months immediately
previous to the filing of this Complaint, however, both having
lived at the above address for approximately four years,
4, The Plaintiff and Defendant were married on October
21, 1972 in Carlisle, Cumberland County, Pennsylvania,
5, There have been no prior actions of divorce or for
annulment between the parties,
SAIDIS, GUIDO
& MASI.ANIl
26 W. High 51 ret.'t
Carlisle. PA
6, The Plaintiff has been advised of the availability of
marriage counseling and the Plaintiff may have the right to
request that the Court require the parties to participate in
counseling, Having been 50 advised Plaintiff does not desire
the Court to order counseling,
7, The marriage is irretrievably broken,
2
-
WHEREFORE, Plaintiff requests Your Honorable Court to
enter a decree in divorce,
Date:
~((,(rr1
Respectfully submitted,
By:
Edward E, Guido, Esquire
Supreme Ct, I,D, * 21206
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Plaintiff
SAlOIS, GUIOO
& MASLANU
26 W. flish SUCCI
Carli!lle. PA
3
.
EDGAR B, PEARSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO,
CIVIL 199
VIENNA M, PEARSON,
Defendant
IN DIVORCE
AFFIDAVIT
I, Edgar B, Pearson, being du ly sworn according to law,
depose and say:
(1) I have been advised of the availability of marriage
counselling and understand that I may request that the court
require that my spouse and I participate in counselling,
(2) I 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 counselling prior
to a divorce decree being handed down by the court,
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,
Dated:
S/,{'i1
~I1, p~
Ed r B, Pearson, Plaintiff
SAIDIS, GUIDO
& MASLAND
26 W. High SHeet
Carlhle. PA
4
VERIFICATION
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, Section 4904,
relating to unsworn falsification to authorities,
Dated:
( I ~ ( 1'-1
~6.P~
Edg r B'-Pearson, Plaintiff
5