HomeMy WebLinkAbout00-04866
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HAROLD J. L YSLE,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00- 4/'1.1:, CIVIL TERM
LINDA A. L YSLE,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
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 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 divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the
Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY,
LAWYER'S FEES. OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHI 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 Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(71 7) 249-3166
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HAROLD J. L YSLE,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00- 'I Pl".L CIVIL TERM
LINDA A. L YSLE,
Defendant
: CIVIL ACTION - LAW
: IN DNORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d)
OF THE DIVORCE CODE
The Plaintiff, Harold J, Lysle, through his attorney, Thomas S. Diehl, makes the
following Complaint in Divorce, and, in support thereof, avers as follows:
1. The Plaintiff, Harold 1. Lysle, is an adult individual who currently resides at 185
North Middlesex Road, Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant, Linda A. Lysle, is an adult individual who currently resides at 185
North Middlesex Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. The Defendant and the Plaintiff have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and the Defendant were married on September 2, 1978 in Carlisle,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Defendant is not a member of the Armed Forces of the United States of
America or its Allies.
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7. The Plaintiff has been advised of the availability of counseling and the right to
request that the Court require the parties to participate in counseling. Knowing this, Plaintiff
does not desire that the Court require the parties to participate in counseling.
8, Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
WHEREFORE, the Plaintiff, Harold J. Lysle, respectfully requests your Honorable Court
to enter a decree in divorce pursuant to 23 P.S. 9 3301(c) or 3301(d) of the Divorce Code.
Respectfully submitted,
~ - "1-00
Date: ( (
-dt!P
omas S. Diehl
Attorney for the Plaintiff
One West High Street
P.O. Box 1290
Carlisle, Pennsylvania 170 I3
(717) 240-0833
(717) 240-0893 -FAX
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VERIFICATION
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. ~ 4904, relating to
unsworn falsification to authorities.
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HAROLD 1. L YSLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, 00-4866
CIVIL TERM
LINDA A. L YSLE,
Defendant
: CIVIL ACTION - LAW
: IN DNORCE
AFFIDAVIT OF SERVICE
AND NOW, this 2 1st day of July 2000, comes Thomas S. Diehl, Esquire, Attorney for the
Plaintiff, Harold J. Lysle, and states that he personally mailed a certified copy of a Complaint in
Divorce to the Defendant, Linda A. Lysle, at 185 North Middlesex Road, Carlisle, Pennsylvania
by certified, restricted delivery, rewm-receipt requested. .. A copy of said receipt is attached
hereto indicating service was made on July 12, 2000.
Thomas S. Diehl
Attorney for the Plaintiff
One West High Street, Suite 208
Carlisle, Pennsylvania 17013
(717) 240-0833
(717) 240-0893 -FAX
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Postage $
.55
1.40
1.25
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Certified Fee
I'- Return Receipt Fee
ru (Endorsement Required)
C Restrioted Oeli'lel"j Fee
C (Endorsement Aequired)
Total Postage & Fees
2.75
$5.95
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r:::J ReCI~/ent's Name (Please Print Clearly) (to be CO~Pf&ls<t bY-ro.ai.lf:I{J.. ",-'
c st:er~~~o.;~;~po~~~!.~~_mnmm.nnm...__:~_:m_~~~'___________..n____
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carlisle, PO 13
.. compl$ieftems1;2, and 3. Also coiilpiilte
lie,!! 4 n Restricted Delivery Is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mallpiece,
or on the front n space parmlls.
1. Article Addressed to:
DAgen!
D Add......
Dyes
D No
LINDA A. LYSLE
185 NORTH MIDDLESEX ROAD
CARLISLE, PA 17013
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3. Service Type
J!'i!:CertlfiedMail
D Registered
CJ 'iXpress Ma!1
CJ RetUrn 'ReCeipt for Merchandise
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4. Restricted Delivery? (E)dIa Fee)
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L Artlcl8 Number (Copy from service label)
7000 0600 0027 7313 2844
S Form 3811. July 1999
Domestic Return Receipt
102595-99-M-1789
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