The URL can be used to link to this page

Home My WebLink About97-04457 t / t'-o ~ ' ~I QJ RLED..QrFiCE G~ ....~r: n~-!-'OmNlY q7 tt:G 15 f:-; 3; 40 CU"",,~ :. . . ~"\'C'( . .... >-, .... ,~., ,. -_~ '...., t PO't .S'/Io_~_;'-.':' ~ '~7S-'SO <..rco . S~+ c.. IC(y \- Ikld '( Cf- $'ftf ,SD c~.Jl ..)~ 'l.t; p.....:1L ..):t;^I70 PATRICK F, LAUER, JR. AUomtyatLaw 2101 MarUI SUM "*" llllildilll CIIlop lfiD. "" 11011 ITln '7U- 1I0ll vs. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. r"t/ I/J/')" / ("., (-r:" }') CIVIL ACTION - LAW IN DIVORCE LORI A. TATE, Plaintiff . , . , , . . . MERL E, TATE, Defendant . . 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 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 Courthouse, Carlisle, Pennsylvania. IF YOU 00 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 SBOOLD TAD 'l'BIS PAPER 'l'O YOUR LAWYBR AT OIICB. IF YOU DO 110'1' BAVB A LAWYBR OR CAIlIIO'1' AFPOlt.D ORB, GO 'l'O OR 'l'ILIlPBOIII 'l'BB OrrICE SIlT POa'l'II BBJ:.OW 'l'O FIIID 0U'l' VBBRB YOU CAN GB'l' LBGAL BBLP. COUIt'l' ADIIlMISTRA'l'OR cutIBIllLUO COUNTY COUll'l'BOUSB 1 COi.)t\i8OUS1l SQOAIUl CARLISUt, PA 17013 (111. 240-6200 LORI A, TATE, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . . . No. (I" '/. "/'J/',',' "~I' { ( y :~., , '-'J ,::, " I CIVIL ACTION - LAW IN DIVORCE vs, , . : MERL E. TATE, Defendant , , COMPLAIN'r IN DIVORCB ONDBR SBCTIONS 3301(c) or 3301(d) OF TUB DIVORCB CODB The Plaintiff, Lori A. Tate, through her attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divorce and, in support thereof, avers as follows: 1. The Plaintiff, Lori A. Tate, is an adult individual who currently resides at 1560 McClures Gap Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Merl B, Tate, is an adult individual who currently resides at 1560 McClures Gap 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. COON'l' I - DIVORCB 4. Paragraph. one through three are incorporated herein by reference. 5. The Plaintiff and the Defendant _re lauded on March 17, 199] in Jaaaica. 6. There have been no prior action. of divo~ or for annul_nt bet_n the partie., 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. This action is not collusive, 10. There are no dependent children to the marriage. COURT II - EQUITABLE DISTRIBUTION 11. Paragraphs one through ten are incorporated herein by reference. 12. The parties have legally and beneficially acquired property, both real and personal, during their marriage. 13. The Plaintiff and the Defendant have been unable, as of the date of this Complaint, to agree as to an equitable division of said property. WBBRBPORB, the Plaintiff, Lori A. Tate, respectfully requests this Honorable Court to enter a decree of divorce in this matter; and the Plaintiff further requests the Court to incorporate any Stipulation reached by the parties regarding the division of marital property into the divorce decree; or, should the partie. fail to reach .uch an agreement, to equitably divide all aarital property. Date' ~/rl.J Ii "1 r Re.~d~ S~bai_t~ed, ~~~, . MIl), ~ Patri F. tauer, Jr., I. . 2108 Market Str..t, Altee Building C.-p Bill, Pennsylvania 17011.C706 to. Cl430 Tel. (717) 763-1800 LORI A. TATE, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . , :i vs. , No. , : MERL E. TATE, . CIVIL ACTION - LAW . Defendant . IN DIVORCE . 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. S 4904, relating to unsworn falsification to authorities. Date: n-\\\-C\\\ Signature: .\.. 0 11~'~- qiT\.\)\ C'\ \u\ \() Lori A. Tate LORI A. TATE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA , . vs, . No. 97-4457 . . . MERL E. TATE, . CIVIL ACTION - LAW , Defendant . IN DIVORCE . PRAECIPB TO WITHDRAW DIVORCB TO THE PROTHONOTARY: Kindly withdraw the above-captioned divorce complaint filed on August 17, 1997 as the divorce has reconciled. " I Date: >ll( Ocl I Respectfully submitted, ~.r...f!J::'quire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 lOt 46430 Tel. (717) 763-1800 It.