HomeMy WebLinkAbout95-01887
i
.3
.
{I
7
i
3
~
F
J I
I
I
I
r-
(YJ
()D ,
- I
,
i
I
,
I
~ ~
.
U l"'-
J~ \"
I t~
-
8 ~
~
,~J - ,.1">
<T)
~.~5~~ -
:'1'::
--4
"" a . '''l
...J ... 'n Q '., ......
_ t.- -
. ... en
,....,
f 0:
u..
-=
(~
@J
~j]~
~ ~~~
citi-8a
~f-i:l:
~]!!
.
DlAN.: G, RAUCI.IH
ATTIII\Nf,\'.AT.I.A\\'
:Utl TRINIII..-. )UlAII
(:AMPIIIU..I'.-\ 17011
6, Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. The Defendant is not a member of the Armed Services
of the United States or any of its Allies.
B. The Plaintiff avers that the grounds on which the
action is based are:
(a) That the marriage is irretrievably broken.
Or in the alternative,
(b) That the parties are now living separate and
apart, and at the appropriate time, Plaintiff will submit an
Affidavit alleging that the parties have lived separate and
apart for at least two (2) years and that the marriage is
irretrievably broken.
WHEREFORE, Plaintiff requests this Honorable Court to
enter a decree in divorce, divorcing the Plaintiff and
Defendant.
COUNT II: EQUITABLE DISTRIBUTIO.
9, Paragraphs 1 through B are incorporated by reference
hereto as fully as though the same were set forth at length.
10, Plaintiff and Defendant have legally acquired
property, both real and personal, during their marriage from
May 19, 1984 until the date of separation, all of which is
"marital property".
3
.
"
VEl.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 95-1887 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
LISA R. WERT,
PLAINTIFF
HOWARD A. WERT
DEFENDANT
ANSWER
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. It is admitted
that Plaintiff avers as grounds for this
action that the marriage is irretrievably broken and that the
parties are now living separate and apart. However, the Defendant
denies that the marriage is in fact irretrievably broken. The
Defendant does admit that while the parties currently continue to
reside at the same address, they are considered to be living
separate and apart.
WHEREFORE, Defendant requests of this Honorable Court that it
not enter a Decree of Divorce in this matter.
9. No further response is necessary.
10. Admitted.
11. Admitted.
12. Admitted.
WHEREFORE, should this Court enter a Decree of Divorce,
.'. W~~,~~~.~~!'t.l,~;,.;,i~r~~~~f~]~*;t~'~*~~!m~{!t~~~~~ '. '
LISA R. WERT, : IN THE COURT OF COMMON PLEAS OF
plaintiff CtMBERLAND COUNTY, PENNSYLVANIA
v. No. 95-1887 CIVIL TERM
HOWARD A. WERT,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE
TO the prothonotary:
please withdrawal the Divorce complaint, which was filed
on April 13/ 1995/ in the above captioned matter and terminate
this action.
~
F, ESQUI E
indle Road
Camp Hill, PA 17011
(717) 737-0100
LD. No. 32112
Attorney for plaintiff