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HomeMy WebLinkAbout95-00697 . - ..- 0'; ~ 3 ~ )' . .( '.~-' ~ ~ ~ QC ~ J -"." J ) Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 95- IN DIVORCE RONALD E, ROWE, JR., Plaintiff v, BARBARA ROWE, WAIVER OF COUNSELING RONALD E. ROWE, JR., being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Office of the prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date~"_~.'H ~ /<j<;';- (' " . ~ ') '5.1 f -;) \.. \o..;:r....."',.\J . ~..kP..f;) '.... RONALD E. ROWE, JR .<::, RONALD E. ROWE, JR., Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95- IN DIVORCE v. BARBARA ROWE, COMPLAINT IN DIVORCE 1. Plaintiff, RONALD E. ROWE, JR., is an adult individual, who currently resides at 237 Louis Lane, Enola, Cumberland County, Pennsylvania. 2, Defendant, BARBARA ROWE, is an adult individual whose current residence is 4 Kelly Court, Enola, Cumberland County, Pennsylvania. 3. Plaintiff avers that he has been a bona fide resident in the Commonwealth of Pennsylvania for a period of six (6) months previous to the filing of this Complaint. 4. The parties were married on July 14, 1979, in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment filed by either of the parties hereto. 6, Plaintiff has been advised of the availability of counseling and that Plaintiff has the right to request that the Court require the parties to participate in counseling, 7. The Defendant in this action is not presently a member of the United States Armed Forces or of any of its allies. ! 8. plaintiff requests the court to enter a decree of divorce. COUNT I 1 I I, I I 9. The averments of Paragraphs 1 through 8 herein are hereby incorporated by reference thereto, 10. The marriage is irretrievably broken, WHEREFORE, Plaintiff prays Your Honorable Court to: (a) Enter a Decree in Divorce, divorcing the plaintiff from the bonds of matrimony heretofore e~isting between plaintiff and Defendant; and (b) Order such other relief as the Court deems just and reasonable. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. !2Jz. PAUL '. E ESQUIRE 320 Mark Street P,O. Box 1268 Harrisburg, PA 17018-1268 (717) 234-4161 Supreme Court ID #25454 Attorneys for Plaintiff By ,;) t:', "" \ . ~ \.)<)\r:) ~") ........ Lr') '.. ~l'\) ......... "- CT> > ;.- v, - ............ ,',.- ~ -;;:) 'Y\ 0 ~ r-\, ,,~ rl P \3-.. ~ .:" ~ .... '" c~"..., ~ 'vo ~ :r-. ~~~ ,'-' ~ L.. - $ - -g:. ... ..... ...... ,...... ~,~ t-'"':,) -! W.t,"'l;,;..:r. O~'-""'4 -0 -'\0 ~:::~~:'J O~- ::~ ":'-'. ;(. i~':; .. '..II.~~u.J ,. "SI'1. ....., ...~c. o ::C .... c> .., ("f)