HomeMy WebLinkAbout94-06845
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Plaintiff
[N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WENDY K, BEAM.
v.
NO. 94. Mll:;' CIVIL
CLIFFORD E. BEAM. JR..
Defendant 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 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 at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pa, 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 (20) days of
the date on which you receive 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, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE R[GHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTlI BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, P ^ 17013
(717) 240-6200
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Plaintiff
[N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WENDY K. BEAM,
v.
NO. 94-
CIVIL
CLIFFORD E. BEAM, JR.,
Defendant
IN D[VORCE
COMPLAINT
1. Plaintiff is Wendy K. Beam, who currently resides at 99 Walmar Manor, Dillsburg,
Pennsylvania 17019.
2. Defendant is Clifford E. Beam. Jr., who currently resides at 360 Peach Glen Road,
Gardners, Pennsylvania 17324.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous 10 the filing of this Complaint.
4. The Plaintiff and Defendant were married on August 31, 1974 in Carlisle,
Cumberland County.
5. There have been no prior actions of divorce or for annulment between lhe parties.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff requests the Court to enter a decree of divorce.
MARTSON, DEARDORFF, WILLIAMS & OTTO
By: -r~ J '^-~ t-1.- ~
Thomas J. Williams. Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: December 2, 1994
WENDY K. BEAM,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
PlaintilT
v.
NO. 94-6845 CIVIL
CLIFFORD E. BEAM. JR.,
Defendant
IN DIVORCE
AFFIDA V[T OF CONSENT
COMMONWEALTH OF PENNSYLVANIA )
: S5.
COUNTY OF CUMBERLAND )
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on
December 2, 1994.
2. The mnrriage of PlaintilT and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. I consent to the entry om final decree of divorce.
4. I understand that [ may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! do not claim them before a divorce is granted.
[ verifY that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject 10 the penalties of 18 Pa. C. S., Section 4904 relating to unsworn
falsification to authorities.
Date:--o/'i'}/q <~
(!fdtAt1' <. <3fJtl~
ClilTord . eam. Jr., Defend t
Sworn to and subscribed before me this
Ib dayof 6 ,1995.
){;(
Nota Public NOI811.,' 5"al
Meliasa A. BOCk. NOIarY Publio I
Carroll Twu.. VOIk Count
I My COUHt.OSlon E.pllos Doc. K. 1007
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