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Home My WebLink About94-04128 '- ~ , , , " I' , '" " " , " , " b '" , ' '- - " .1,111\',1 , " ./ / r (i ~: JI . I I " ',0 " " " " ',,, e ~ 5 lI'l ,., 9 J ~y ~ I- ~ 1 .,j "1 t~ . cj . , ~ t~ ~ ... '.';ffr-, , . "~" ,0' ..J,.,.' ,. . " ~ ''1 \ . '0 ~ '- -, () ... ~ . 'ol ...J l; ...... ,n '" Et -, '~ . ~\" " . '. -r _ i " '.JfJ 'I ...\ .~, " L ' "") ~~.J IV' ,4" "-.:.J r\ \~ ,- ~ i\ -.....! '-..J - :r l.(j ("~ - , ~ < ~ Ul< <I> ~4 H ...1 >< Il<Ul ... ., .'. 'H " _. ~~ 'M . oj Or4 -., P:; 'd ~p... p:; ,1 1.>1 " S :>: w...... <:J " . " 0 . :- <:J III ~'H ~ C . 0>< III h-.. ~l H " ,.. ,~ ... E~ ...1 H P. ...1 A ~ c"" 0' f>o~ ...:1 po: ~ c ,." 0:::> po: .~ Ii ,0" - . 0 .~ " t~ 0 >:F. E"o " '-" p ~ ... W . - ~ 0 . I ~ ':: z :::>A 'd j:l.J " ~ ~ .'. 00' I .,U po: ~ 0 2~3 ...' (.) <_-.r 0'" .. u . ,-, ...:1 "'< 0 ~ ro.1 . ~p:;", I> .~ PC: rz: r.l rl M H ~.1 ~~ E-<~ 'rl A A ~, :>: . > ~p o ',-i ~ H(.) I&!: UH '> " .. .~ ~ \ ) '''"' -- '11:- 'i'\""l/:' 1~ (\/'tI/ ("OlHI&fl.OR AT LAW 10" Jilt, VIIW [lit IN01,., ,... 1702" ,.,tOHI 171711.12 '1I1S1 DEAN R. GARLINGER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA qlL- Lj.1J.~ : NO, '1" CIVIL TERM va KAREN J, GARLINGER, Defendant : CIVIL ACTION -LAW : IN 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 fall 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 grounds for the divorce Is indignities or Irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is avail- able in the office of the Prothonotary at: CUMBERLAND COUNTY COURTHOUSE, Carlisle, Pennsvlvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PERSONAL PROPERTY. LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED. YOU MAY I-OSE 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 TE~IEjP~ONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator, Third Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone: 1-249-1133 8, The Plaintiff has been advised of the al/allablllty of marriage counseling and that the Plaintiff and Defendant hal/e the right to request that the Court require the parties to participate In counseling. 9, The partl8s have not entered Into any written agreement for property dll/lslon; there are no children born to the parties In or out of the marriage, C911NT 1 Reque.t for I No-Flult Oll/orce Under Section 3301(c) of the Divorce Code 10, Paragraphs 1-9 of this Complaint are incorporated herein by reference thereto, 11. The marriage of the parties Is Irretriel/ably broken. , 2, After ninety (90) days have elapsed from the date of filing of this Complaint, Plaintiff Intends to file an affidavit consenting to a divorce, Plaintiff believes that Defendant may also file such an affldal/it. 13, Plaintiff has been advised of the availability of marriage counseling and that the Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling, WHEREFORE, if both parties file affidal/its to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301 (c) of the Divorce Code, . , I v. IN THB COURT OF COMMON PLBAS CUMBBRLAND COUNTY, PBNNSYLVANIA NO. 94-4128 CIVIL ACTION - LAW IN DIVORCB DBAN R. GARLINGBR, Plaintiff KARBN J. GARLINGBR, Defendant 1. 2. 3. 4. 1993. 5. 6. 7. e. 9. DBFBNDANT'S ANSWBR TO COMPLAINT IN DIVORCB Admitted. Admitted. Admitted. Denied that the parties were married on September 12, The parties were married September 12, 1992. Denied that the marriage iB irretrievably broken. Admitted. Admitted. Admitted. Admitted. COUNT 1 10. No reeponBe required. 11. Denied that the marriage of the parties is irretrievably broken. 12. No responee required. 13. Admitted. WHBREFORE, the Dofendant reepectfully requeats this Court to dismiss the Complaint in Divorce. COUNT 2 14. No responB8 required. 15. Denied that Defendant hae committed any indignities to Plaintiff rendering his condition intolerable and life burdensome. . ... .. v. I IN THB COURT OF COMMON PLBAS I CUMBBRLAND COUNTY, PBNNSYLVANIA I I NO. 94-4128 I I CIVIL ACTION - LAW I IN DIVORCE DIAN R. GARLINGIR, plaintiff KARIN J. GARLINGER, Defendant DBFBNDANT'S RBOUEST FOR ORDER REOUIRING COUNSELING The Defendant, Karen J. Garlinger, by and through her attorneys, Mirin & Jacobson, files this request for counseling as provided in 23 P.S. S 3302 and statesl 1. The Plaintiff filed a divorce complaint under Section 3301(c) or 3301(a) (6) of the divorce code on July 25, 1994. 2. The Defendant believes that marital coun8eling may be of benefit in preventing the dissolution of this marriage. WHEREFORE, the Defendant, Karen J. Garlinger, respectfully requ~sts this Court to enter an Order requiring the parties to attend three lIIessions of marriage counseling as provided in 23 P.B. S 3302 and to assess the costs for the counseling sessions equally between the Plaintiff and the Defendant. Respectfully submitted, MIRIN & JACOBSON DATED: Auaust 24. 1994 8150 Derry Street Harrisburg, PA 17111-5260 (717) 561-1515 BY~~!\ (~)i~-f-t,,-,- M. Peter Harer Attorney I.D. No. 65604 Attorney for Defendant garlcoun. req