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DITTY A. HARRY,
Plaintiff
IN THI COURT OF COMMON PLBAS
CUMBIRLAND COUNTY, PBNNSYLVANIA
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CIVIL TRIAL
DIVORCI
V.
NO.
BDWARD F. HARRY,
Defendant
CONJILaJ:1I'l III DIVO.C~
AND NOW come. the Plaintiff, Betty A. Harry, by and through
her attorney, Charles Rector, .squi&e, of Costopou1os, Foster &
Fields, and respectfully represents as follows 1
1. Plaintiff is Betty A. Harry, who currently re.ides at 9
King Drive, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Edward'. Harry, who currently re.ides at 9
King Drive, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residente of
the Conunon",eal th of Pennsylvania for a periOd of six (6) months
immediately preceding the filing of the Complaint.
4. Plaintiff and Defendant were married on July 2, 1947, in
Frederick, Maryland.
5. There have been two prior actions of divorce between the
parties commenced in 1954 and 1961, which actions were dismissed.
6. The Plaintiff and Defendant ars both citizens of the
United States of "-eriea.
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CO~ I - DIVORCE
7. The allegations of peragraphs 1 through 6 are
incorporated herein by referance and made a part hereof.
8. Thie aotion ie not brought through collusion betwsen the
Plaintiff and Defendant, but in sincerity and truth for the reasons
set forth within.
9. The marriage i. irretrievably broken, and the Partie. are
proceeding under Seotion 3301(0) of the Divorce Code.
10. Plaintiff has been advised that counseling ie available
and that Plaintiff may have the right to reque.t that the Court
require the partie. to partioipate in coun..ling.
COUlfT II
EOUITABLE DISTRIBUTION
11. Paragraph. One through Ten of this Complaint are
incorporated herein by reference a. if .et forth at length.
12. The partie. have acquired, during the oouree of the
marriage and prior to .eparation, property, both real and personal,
whioh they own jointly or which was otherwise purohased so a. to
constitute "Brital property within the definition and scope of
Seotion 3502 of the Divorce Code.
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