HomeMy WebLinkAbout02-61571N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ROBERT P. LANG, )
Plaintiff )
)
v. )
)
PATRICIA W. LANG, )
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 Office of
the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania
17013.
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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ROBERT P. LANG, )
Plaintiff )
)
v. )
)
PATRICIA W. LANG, )
Defendant )
CIVIL ACTION - LAW
1N DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO §3301(c) OR (d)
OF THE DIVORCE CODE
AND NOW, comes Plaintiff, Robert P. Lang, by and through his counsel, Howett,
Kissinger & Conley, P.C., who hereby files the instant Complaint in Divorce and in support
thereof avers as follows:
1. Plaintiff is Robert P. Lang, an adult individual who currently resides at
429 Meeting House Road, Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant is Patricia W. Lang, an adult individual who currently resides at
429 Meeting House Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. Both Plaintiff and Defendant have been bonafide residents of the
Commonwealth of Pennsylvania for a period of at least six (6) months immediately preceding
the filing of this Complaint.
Plaintiff and Defendant married on June 9, 1973 in Pittsburgh,
Pennsylvania.
5.
Neither Plaintiff nor Defendant is in the Military or Naval Services of the
United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of
the Congress of 1940 and its amendments.
6. There have been no prior actions for divorce or annulment of this mamage
instituted by either of the parties in this or any other jurisdiction.
7. Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to request that the court require the parties to participate in counseling.
8. The marriage of the parties is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests the Court enter a Decree of Divorce
Pursuant to §3301 of the Divorce Code.
Respectfully submitted,
Date:
Darre J. pd~t, Esquire
HOWETT, KISS1NGER & CONLEY, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff, Robert P. Lang
VERIFICATION
I, Robert P. Lang, hereby swear and affirm that the facts contained in the foregoing
COMPLAINT IN DIVORCE
are
tree and correct to the best of my knowledge, infoimation and belief and are made subject to the
penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities.
Date: 1
2/26/02 l~b~rt P. Lang '
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ROBERT P. LANG, )
Plaintiff )
)
v. )
)
PATRICIA W. LANG, )
Defendant )
NO. 02-6157 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Patricia W. Lang, Defendant in the above-captioned divorce action, hereby accept
service of the Complaint in Divorce Pursuant to §3301(c) or (d) of the Divorce Code.
Pa~tricia W. Lang, Defer~d~ant /J