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Home My WebLink About95-01396 Oo9660-0000IIMln:h' 13, 1995/JLHIMHI4ZZ60 BONITA K. POOLE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 1:.J-. /J9~ (J.M,LLL~LL-l Plaintiff vs. IN DIVORCE DAVID L. POOLE, Defendant 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 pages 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 Indignitie.~ or irretrievahle breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is availahle in the Oflice of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 I Courthouse Square Carlisle, PA 17013-3387 Telephone: (717) 240-6200 Oo9660-0000IlMln:h 13, 1995IJLHIMHl4~~60 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. BONITA K. POOLE, vs. IN DIVORCE DAVID L. POOLE, Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 330Uc) OR 330Ud) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Bonita K. Poole, by her attorneys, Johnson, Duffie, Stewart & Weidner, and files this Complaint In Divorce of which the following Is a statement: I. The Plaintiff, Bonita K, Poole, is an adult individual residing at 1431 Maplewood Drive, New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant, David L. Poole, is an adult individual residing at 1513 Terrace Avenue, Carlisle, Cumberland County, Pennsylvania, 3. The Plaintiff and Defendant have been bona fide residents In the Commonwealth for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 24, 1979, in Carlisle, Cumberland County, Pennsylvania and separated on or about July 16, 1994, 5. There have been no prior actions for divorce or annulment between the parties, 6. The Plaintiff has been advised of the availability of marriage counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling, 7. The marriage is irretrievably broken. Oo9660-0000IIMI"'h'I3, 1995',JLHIMW42260 WHEREFORE, Plaintiff, Bonita K. Poole. requests this Honorable Coun to enter a decree of divorce to Plaintiff and Defendant as if they had never been married. JOHNSON, DUFFIE, STEWART & WEIDNER Date:) -I "'1' "'15 By . oseph I.:. Hitchings Allorney 1.0. No, 65551 30 I Market Street P,O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Allorneys for Plaintiff I verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C,S.A A4904. relating to unsworn falsification to authorities, Date: .(- /4-9...7 , ~//'~64~- Bonita . Poole ,~~ '-........,.~ ?::... ~ ,..... .-..l. "'l- ~ -- ~ ~ '-.l.J ...... '- v., D ~ <-> ~c......' . I v.. N ____, C't~ ~ ,s:~.. r ~.~ ::., ~T - ~~;J '.:~ I'J... :~~;;'i~ ;~: ~,~ 7: 0 I..~ '''' , ':':.~ "':' ~ C .:-l- ~~ .......... c.. \l 5l. UV . \ ....' c- c;,> , . ::c - ::0 - -.I !'oJ ~ .... ::x: - ~ 009660-0000IlMay'24. 1995/JLIlIMIlI44085 BONITA K. POOLE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-1396 Plaintiff vs. DAVID L. POOLE, CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDA VIT OF CONSENT I. A Complaint in divorce under Section 3301(c) of the Divorce Code was tiled on March 17. 1995. 2. The marriage of Plaintiff and Defendant is irretrievahly broken and ninety days have elapsed from the date of filing the Complaint, 3. I consent 10 the entry of a tinal decree in divorce. 4, I understand that I may lose rights concerning alimony, division of property. lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have heen advised of the availahility of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and 110 participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Aflidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa.C,S. fi4904 relating to unsworn falsification to authorities. Date:Jft~/q" ( ~('~,f:~d . Bonita K, Poole. Plaintiff 009660-0000IIMay:4, 19951JLHIMHl44085 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-1396 BONITA K, POOLE. vs. DAVID L. POOLE, CIVIL ACTION - LAW IN DIVORCE Defemlant AFFIDA VIT OF CONSENT I. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on March 17, 1995, 2. The marriage of Plaintiff and Defendant is irretrievahly broken and ninety days have elapsed from the date of filing the Complaint, 3. I consent to the entry of a tinal decree in divorce. 4. I understand that I may lose rights concerning al imony. division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming tina!. I verify that the statements made in this Aftidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, ~4904 relating to unsworn falsification to authorities. . i.A",,';r:; o.,W<J '. . (} . ~:='~J~~';tt- I tJ~m . David L. Poole, Defendant -' ..... , l"~.~l. .='.:'i'"."i,,~.::;...........,....::....,.i.'..':':', ;'.......,.. ,'. '.'. '.'. I'" ,..:,' ,~~....~ji?,tiJ ~dlf.~~~l-.u..a "" 1ddidonoI........";,: ",,' ,1110 'w...h, tel '~r";,.l"':'"'",~ Ilf~~;~~'~=~;1::1::.;:zt ::r~~;:~:~~;~P:J! 1;'.'.:W!,Ilo~ftoCoIpl"-"""'"''''_boIow''''IIlIcIo''''''''' .., , A"",;~l;c,i "I' .,;a~.'1Ilo_ftoCoIpl"'_"w""'''''_w,,_''''tM_ 2. ~ ~ ~r., '~ I ';.8'_"'>' "~,, ClllIIUh _fOlfN, " I !~'I'? 3;'l\rtIcll AddrtllHd tel: " 41. AllIcIt Number ' ~:" ""j: .' ~"i':'" Ie', ' ...... 070 7"8 790 """: r ~'~"")' Q - U -' . ., '-' , I';' .;:o&Vid';J;. Poole ~. Slrvlce Type ',' " :' t ; \~; ?~,1~~~ A~U' ~ ~:~~red " g ~"'.'.'...;':.'.;I'~: , , ',' 0 Elcpr_ MIll .. 0 RllUm RfCleI~,~l.' .~ , . '.I' :: ;'k~ ." _, 0 Of:_~I~,'1 ~.,_:/i~r:';i:i};i'-~-l:::l'< ,j't;':'::;, ;,;'.i," It/"..~, ~;,j.',,<;j'''>:'''_~'.~_~'I;''~:: Ii ii' ~,~~~i~i/~.1 llU.LCIl'lII1__Tl4 DOMESTIC RETURN RECElPT[t!: II J i" "...(,'>,':'tr':.11,:1[it~til "'~-'- 1 I I . 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