HomeMy WebLinkAbout94-05741
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ROBYNN HOPE,
IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
1994 - 57 Lf I
CIVIL TERM
MICHAEL L. HOPE,
Defendant
DIVORCE
.
.
_OTICB TO DB~BND 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 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 Courthouse,
First Floor, Carlisle, Pennsylvania 17013, Telephone: (717)-240-
6195.
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.
Court Administrator
Cumberland County Courthouse
Fourth Floor
Carlisle, Pennsylvania 17013
Telephone (717)-240-6200
ROBYNN HOPE, IN THE COURT OF COMMON PLEAS OF
.
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . 1994 CIVIL TERM
.
.
.
MICHAEL L. HOPE, . DIVORCE
.
.
.
Defendant .
.
COMPLAINT IN DIVORCB
The plaintiff by her attorney, R. MARK THOMAS, ESQUIRE,
brings this action in divorce for a Decree of Divorce from the
bonds of matrimony and respectfully represents:
1. The plaintiff is ROBYNN HOPE, an adult individual, who
currently resides at 10-A Richland Lane, Apt. 101, Camp Hill,
CUmberland County, Pennsylvania 17011.
2. The defendant is MICHAEL L. HOPE, an adult individual,
who currently resides at 116 S. 18th street, camp Hill, CUmberland
County, Pennsylvania 17011.
3. Plaintiff and defendant have been bona fide resident. of'
september 16,
Pennsylvania.
1989,
in Mechanicsburg,
CUmberland
counq:,'
the Commonwealth for at least 6 months immediately previous to the
filing of this Complaint.
4. The plaintiff and defendant were married
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintitt has been advised ot the availability ot
marriage counseling and that she may have the right to request the
court to require the parties to participate in such counseling.
WHEREFORE, the plaintitt requests the Court to enter a
Decree in Divorce.
COURT II - IQUITABLB DISTRIBUTION
8. Paragraphs 1 through 7 are incorporated herein as it set
forth in their entirety.
9. The plaintiff and defendant have acquired property, both
real and personal, during the life of their marriage.
10. The plaintiff and defendant have been unable to agree as
to the equitable division of said property.
WHEREFORE, the plaintift requests this Honorable Court to
equitably divide all marital property.
Respectfully submitted,
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R. Mark Thomas, Esquire
54 E. Main street
Mechanicsburg, PA 17055
(717) 697-4650
I.D.* 41301
Attorney for Plaintiff
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VERIFICATION
I verity that the statements made in this Complaint are true
and correct. I understand that talse statements herein are made
subject to the penalties ot 18 Pa. C.S. 54904, relatinq to unsworn
talsitication to authorities.
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