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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
95- t'O?J..... CIVIL TERM
WILLIAM H. SMITH,
Plaintiff
JOYCE J. SMITH,
Defendant
IN DIVORCE
NOTICE
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 in the
Office of the Prothonotary at the Cumberland County Court House,
High and Hanover Street, Carlisle.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A 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 Court House
1 Courthouse Square
Carlisle, PA l7013
(717) 240-6200
(/,y
Robert C. Saidis, Esq.
Attorney for Plaintiff
WILLIAM H. SMITH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
95 '. S(lf ~ CIVIL TERM
JOYCE J. SMITH,
Defendant
IN DIVORCE
COMPLAINT UNDER SECTION 3301lcl
OR 3301ldl OF THE DIVORCE CODE
1. Plaintiff is WILLIAM H. SMITH, who currently resides at
175 Airport Road, Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is JOYCE J. SMITH, who currently resides at
175 Airport Road, Shippensburg, CUmberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents
in the Commonwealth for at least six months immediately previous
to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February 27,
1987 in Shippensburg, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The Plaintiff has been advised of the availability of
marriage counseling and the Plaintiff may have the right to
request that the Court require the parties to participate in
counseling. Having been so advised Plaintiff does not desire the
Court to order counseling.
SAIDIS, GUIDO,
SHUFF &<
MASLAND
~fl W Ullh Stl't"C'l
Carh,le, VA
7. The marriage is irretrievably broken.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
a decree in divorce.
COUNT I I
8. The allegations in paragraphs one through seven,
inclusive, are made a part hereof and incorporated herein by
- _.......
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND :SS
I verify that the statements made in this Complaint 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.
DATED:
tis.
/).. " /.-
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William H. Smith Plaintiff
WILLIAM II. SMITII
,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
95-
CIVIL TERM
JOYCE J. SMITH
,
Defendant
IN DIVORCE
AFFIDAVIT
I, WILLIAM II. SMITII
, being duly sworn according to
law, depose and say:
(1) I have been advised of the availability of marriage
counselling and ~nderstand that I may request that the court requir.e
that my spouse and I participate in counselling.
(2) I understand that the court maintains a list of marriage
counselors in the Prothonotary's Office, 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 counselling prior to a divorce
decree being handed down by the court.
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.
Dated:
9/S-/9'~-
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William II. Smith, Plaintiff