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HomeMy WebLinkAbout02-4658ROBERT LOWRY, Plaintiff KAREN LOWRY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA _. : : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTfi 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 grounds for the divorce are 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 Courthouse. 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) i ROBERT LOWRY, Plaintiff V. KAREN LOWRY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OR SECTION 3Rnl__~D) OF THE DIVORCE DECREE COD~' AND NOW, comes the Plaintiff, Robert Lowry, by and through his attorney, of The Law Office of Darrell C. Dethlefs, seeks to obtain a Decree in Divorce from the Bonds of matrimony with the above-named Defendant and in support of her Complaint avers the following: 1. Plaintiff, Robert Lowry, is an adult individual, who currently resides at 560 Boxwood Lane, Carlisle, Cumberland County, Pennsylvania. 2. Defendant, Karen Lowry, is an adult individual, who's address is unknown. However, she receives mail at 560 Boxwood Lane, Carlisle Pennsylvania. 3. Plaintiff has been a bonified resident of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on May 5, 1997 in Carlisle, Pennsylvania. 5. The Plaintiff and Defendant are citizens of the United States of America. 6. The Plaintiff is a member of the United States Army National Guard. Defendant is not a member of the Armed Services of the United States or any of its allies. 7. Plaintiff has been advised of the availability of counseling and that she and the Defendant may have the right to request that the Court require the parties to participate in such counseling. 8. The parties mander into a written agreement with regard to support, alimony, and property division. In the event that such an agreement is entered into, the agreement may be incorporated by the Court into the final decree of divorce. COUNTI REOUEST FOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWn" UNDER 3301¢C~ OF THE DIVORCE CODF The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that the Defendant may also file such an affidavit consenting to a divorce. 12. Plaintiff has been advised of the availability of counseling and that she and the Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits consenting to divorce after ninety (90) days have elapsed from filing of the Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(C) of the Divorce Code. 13. COUNT !! REOUEST FOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWN UNDER 3301¢D~ OF THE DIVORCE COD_F The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 14. The Marriage of the parties is irretrievably broken. 15. After a period of two (2) years has elapsed form the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. 16. Plaintiff has been advised of the availability of counseling and the Plaintiff and Defendant have the right to request the Court to require parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed his affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(D) of the Divorce Code. Date: Respectfully. Submitt_ed;~ By: Michael J/Pykosh, Esquire Attorney'l.D. 58851 P.O. Box 368 Camp Hill, PA 17001 (717) 975-9446 Attorney for Plaintiff ROBERT LOWRY, Plaintiff KAREN LOWRY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE I hereby verify that the statements of fact made in the foregoing Complaint in Divorce, are true and correct to the best of my knowledge, information and belief. ~ understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Robert Lowry ~// * -