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MICHAEL GEARY MCCLOSKEY,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. qL{ - ~ &./-7~ t1~ T.iMtv
CIVIL ACTION - LAW
IN DIVORCE
LOUANN S. MCCLOSKEY,
Defendant
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 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, Dauphin County Courthouse, Front and Market Streets,
Harrisburg, Pennsylvania 17101. You are advised that this list is
kept as a convenience to you and you are not bound to choose a
counselor from the list. All necessary arrangements and the cost
of counseling sessions are to be borne by you and your spouse. If
you desire to pursue counseling you must make your request for
counseling within TWENTY DAYS (20) of the date on which you
received this notice. Failure to do so will constitute a waiver of
your right to request counseling.
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 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 LAWYER REFERRAL SERVICE
Cumberland County Court Administrator
Cumberland County Courthouse - 4th Floor
1 Courthouse Square
CarliSle, Pennsylvania 17013
Charle. J. Hartwell, ..quire
Supreme court I. D. No. 52655
Bo.well, snyder, Tintner , Piccola
315 North Front Street
P. O. Box 741
Harri.burg, PA 17108-0741
(717) 236-9377
MICHAEL GEARY MCCLOSKEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
CIVIL ACTION - LAW
LOUANN S. MCCLOSKEY,
Defendant
IN DIVORCE
mmLAINI
1. The Plaintiff, Michael Geary MCCloSkey, is an adult
individual who currently resides at 4770 Brian Road, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
2. The Defendant, Louann S. McCloskey, is an adult individual
who currently resides at 4770 Brian Road, Mechanicsburg, Cumberland
County, Pennsylvania, 17055.
3. Plaintiff has been a bona fide resident of the Common-
wealth of Pennsylvania for at least six months immediately prior to
the filing of this Complaint,
4. The Plnintiff and the Defendant were married on October
14, 1989, at Mechanicsburg, Pennsylvania.
5. The parties separated on or about April 13, 1994.
6. Neither party has instituted any prior action of divorce
or annulment with regard to this marriage in this or any other
jurisdiction.
.
MICHAEL GEARY MCCLOSKEY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. . NO.
.
. CIVIL ACTION - LAW
.
LOUANN S. MCCLOSKEY, I
Defendant . IN DIVORCE
.
~
I, MICHAEL GEARY MCCLOSKEY, Plaintiff, verify that the
statements made in the foregoing Complaint are true and correct.
I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S.A 54904, relating to unsworn falsification
to authorities.
d ~~iG:i.!l~-4J LkcC~r
~ CHAEL G Y MCCLOS 1:
DATE: '74{ay- 9
f
, 1994