HomeMy WebLinkAbout94-04947
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WINIFRED M. WORK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN DIVORCE
vs.
MARK E. WORK,
Defendant
COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, Winifred M. Work, by and through
her attorney, Charles Rector, Esquire, of Costopoulos, Foster &
Fields, and respectfully represents as follows:
1. Plaintiff is Winifred M. Work, who currently rea ides at
715
New Cumberland,
Cumberland
County,
Barbara
Street,
Pennsylvania.
2. Defendant is Mark E. Work, who currently resides at 715
Barbara Street, New Cumberland, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of
the Commonwealth of Pennsylvania for a period of six (6) months
immediately preceding the filing of the Complaint.
4. Plaintiff and Defendant were married on May 23, 1987, in
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The Plaintiff and Defendant are both citizens of the
United States of America.
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COUNT I - DIVORCE
7. The allegations of Pangnphs 1 through 6 are
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incorporated herein by reference and made a part thereof.
8. This action is not brought through collusion between the
Plaintiff and Defendant, but in sincerity and truth for the reasons
set forth within.
9. The marriage is irretrievably broken, and the Parties are
proceeding under Section 3301(c) of the Divorce Code.
10. Plaintiff has been advised that counseling is available
and that Plaintiff may have the right to request that the Court
require the parties to participate in counseling.
COUNT II
~UITABLE DISTRIBUTION
11. Paragraphs One through Ten of this Complaint are
incorporated herein by reference as if set forth at length.
12. The parties have acquired, during the course of the
marriage and prior to separation, property, both real and personal,
which they own jointly or which was otherwise purchased so as to
const! tute marital property wi thin the definition and scope of
Section 3502 of the Divorce Code.
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I verify that the statements made in this Complaint are true
and correct. I understand that false statements hexein are made
subject to the penalties of 18 Pa.e.S. Section 4904, relating to
unsworn falsification to authorities.
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Wi~red M. Work